Which? Annual Report

Annual report and financial statements of the Consumers’ Association 2020-21

Note: A small technical revision has been made to our 2020–2021 Annual report and financial statements, which can be viewed in the downloadable pdf

Thank you for helping to make life simpler, fairer and safer for all UK consumers.

Continued uncertainty has impacted all our stakeholders throughout the year, including consumers, businesses, policy makers and employees.

We’ve achieved a solid financial performance through innovation in our subscription model and the development of non-subscription revenue streams, and increased our reserves.

We’ve seen a healthy growth in traffic through relevance and availability of our expert content, and we are aiming for a broader and more diverse audience to benefit from our advice.

Our advocacy work is delivering change for consumers, from our work on Covid-19 travel refunds to scams.

Sustainability and diversity are becoming embedded across the organisation after significant focus in 2020/21.

Delivering our digital transformation has proved more challenging than we had hoped and will continue to be an ongoing focus for 2021/22.

We are finishing the year in a strong position to deliver our three-year vision, with engaged employees, a strong balance sheet and a clearly-aligned strategy.

Welcome from the Chair of the Consumers’ Association

My first full year as Chair of the Consumers’ Association has been challenging and rewarding in equal measure – challenging because of the continuing restrictions imposed on all of us by the pandemic, rewarding because of the remarkable progress the organisation has made nonetheless.

Consumers have continued to be confronted with a confusing and unstable environment in which I believe Which?’s role has been more important than ever.

Update from  the Chair of  Which? Limited Board

I’m happy to report that we have seen strong commercial momentum over the past year, thanks to our determination to press on with our ambitious commercial strategy, despite the overall uncertainty in the world around us.

Having a strong and successful commercial business is vitally important: it is the income from our paid-for services that enables our independence and funds the delivery of our charitable purpose.

Chief Executive’s Welcome

It has been another turbulent year for all of us at Which? – but we haven’t let the pandemic hold us back in our mission to be the UK’s consumer champion.

Many businesses and charities have been forced to batten down the hatches, just focusing on getting through an extraordinarily difficult time.

Which?, on the other hand, has kept moving forward. With strong foundations, we have been able to work towards emerging from Covid-19 in better shape than ever before – our own version of building back better. As with every year, we started from the point of considering the needs of UK consumers.

At Which?, we are defined by our role as the driving force for positive change for all consumers across the UK, and I am pleased to say it has been another year of significant wins. Our landmark claim against US chip manufacturing giant Qualcomm made headlines and could result in a multi-million-pound payout for UK mobile phone users.

We responded to a surge of scams during the pandemic with our scam alert service, which has had more than 300,000 sign-ups. We continue to challenge bad practices where we see them and are sending a clear message that manipulative practices, abuses of power and failures to protect consumers are unacceptable.

Council of Trustees Report (incorporating strategic report)

Overview of the year

As we reflect on another year of uncertainty brought about by the ongoing pandemic, our purpose – to make life simpler, fairer and safer for everyone – resonates more powerfully than ever. New challenges, such as the aftermath of Brexit and an increasingly digitalised landscape for consumers, means that we must work hard to remain relevant to consumers.

As a self-funded charity, the Consumers’ Association must have long-term financial stability, enabling us to achieve our charitable purpose and deliver important positive impact for consumers. We generate our own revenue through our commercial arm, Which? Limited, and don’t rely on grants or donations. Delivering our strategy and vision requires us to stabilise and ultimately grow our subscriptions revenue (2020/21: £75.4; 2019/20: £77.5), while simultaneously building the income from our other commercial services, such as our endorsement scheme and our Legal and Trusted Trader offerings. We’ve made good progress in year which you can read more about in this report.

As we look ahead, it is clear that the work we have done on our strategy over the past two years has laid the solid foundations for us to clearly and confidently set out our vision for the future and the actions we will take to make this a reality.


As with diversity and inclusion, we’ve been taking steps to embed sustainability across all areas of the business, both internally and externally. Externally we have launched initiatives such as the Eco Buy endorsement, which assesses the repairability, longevity and energy-efficiency of products, and have launched a new, free sustainability email update and we are trialling a new podcast series.

Internally we have made a number of green changes in our offices and in key business areas to offset the carbon we generate, including the products we test.

Three-year vision

By 2024 we’ll be the UK’s most famous brand for championing consumers. Everyone will know we make life simpler, fairer and safer by offering independent advice, influencing businesses and policymakers, and tackling even the most sophisticated online consumer harm. We’ll have more members who are representative of our diverse society today, deepening our insights and giving us a more powerful voice. New revenue streams will mean more for us to spend on protecting consumers. Our free offer will make us more accessible, so more people will know that Which? is on their side.

Our products and services will be a breeze to use, with every experience more personalised. And our content will have more direct impact, appearing more regularly in the right channels at the right time.

Sustainability will be second nature to us, and we’ll be unmistakably diverse and inclusive – more flexible in the way we work, with systems and processes that make it quick and easy for us to get our best work done. By 2024 we’ll be more relevant to more consumers, a bigger part of their daily lives than ever before.

Who we are

Which? is the UK’s consumer champion. As an organisation, we’re not for profit and all for protecting consumers – a powerful force for good, here to make life simpler, fairer and safer for everyone. We stand up for what’s right for consumers, their experiences drive us to make things better.

Our parent charity, the Consumers’ Association, is funded by our commercial subsidiaries. They generate income from membership subscriptions and businesses whose products or services earn our endorsements can, for a fee, use our name to promote them. We’re not influenced by third parties and we don’t accept freebies from product manufacturers or retailers.

We stand up for what’s right for consumers, their experiences drive us to make things better. Our research gets to the heart of the consumer issues that matter, and our expert advice is completely impartial. Same goes for our product reviews – our rigorous tests and expert recommendations help consumers to make better decisions. We investigate and make change happen – from tackling online scams to campaigning for safer products, we’re the independent consumer voice that influences politicians and lawmakers and holds businesses to account.

Everything we do is about championing consumers. We’ll always be on their side, fighting their corner and working to make them more powerful.

Financial overview

Our parent charity, the Consumers’ Association, increased the allocation of resources to delivering our charitable purpose, with charity spend increasing to just over £23.5m (2019/20: £21.9m). This spend is wholly funded by our commercial business.

After the allocation of charitable spend, together with non-trading income and costs, our net commercial activities generated a further £4.3m of profit, which combined with realised and unrealised gains on our investments of £4.8m, has more than offset a £1.8m loss on the revaluation of the pension scheme to deliver an increase in the Group’s reserves of £7.3m. The carried-forward reserves of £59.7m provide a healthy reserves position.

How we helped consumers this year

We tackle consumer harm by making life simpler, fairer and safer for everyone. Our purpose has never been more important. It informs both our advocacy and influencing work and our commercial services.

We focus our support for consumers in four main areas: consumer rights, digital life, scams and money.

Our impact for consumers

This was a strong year making positive change happen for consumers. These examples show the different ways we created impact this year:


Directly supporting millions of consumers to deal with the challenges they faced this year, including via our rolling responsive programme of Covid19-related advice on travel, consumer rights and finances and our rapidly growing weekly scams alert email. We added new services and advice to help us grow our impact, including a mobile switching service, a new Eco Buy endorsement and a scams reporting tool.


Taking on big businesses when they haven’t been playing fair, and driving better enforcement. We successfully challenged regulators to clamp down on companies we felt could do better, driving investigations into airlines’ unfair refund practices and online platforms’ inaction on fake reviews. We also flexed our legal muscles with a collective redress legal challenge to the tech giant Qualcomm for systemic overcharging which could see mobile phone customers able to claim back millions.

Making consumers’ lives simpler

We supported consumers to make informed decisions about the things they buy, making it easier for them to avoid goods or services more likely to disappoint, with new Eco Buy advice introduced this year to help those who want to buy more sustainably. We also helped hundreds of thousands of consumers who might otherwise have found it difficult to take action that would benefit them (e.g. making a complaint or switching utility provider), including by expanding our support to include a new mobile switching service. Take-up of our practical support increased this year as we were able to respond to new difficulties or priorities created by Covid-19 – e.g. as we saw more interest in advice on using the internet to stay in touch during lockdowns and more interest in will-making because of the health threat of the pandemic.

85% of consumers who see our endorsement logo while shopping say that it makes them less worried about choosing the wrong product or wasting their money
consumers reassured by our logo

Making consumers’ lives fairer

Our helplines supported consumers to tackle more than 75,000 money, legal and computing problems, and our online claims tools helped more than 40,000 consumers seek redress after problems with goods and services – e.g. refund claims for travel disrupted by Covid-19. Our investigations, campaigns and policy work protected consumers from being short-changed by unfair business practices as we successfully challenged businesses selling online with inadequate refund policies, insurance companies offering poor Covid-19 protection for travellers, and online marketplaces tolerating fake reviews. We continued to fight to make sure no consumers are unfairly ‘left behind’ in an increasingly digital world, with our leadership of the national fast-fibre broadband Gigabit Taskforce (gigaTAG) influencing government thinking on how to ensure all consumers can benefit from the best available broadband service, and our cash campaign winning firm commitments from banks and big businesses to protect cash for those who need it.

The estimated value of the refunds paid out to consumers using our online claims tools is £14m
value of refunds via online claims tool

Making consumers’ lives safer

We have reduced the risk to consumers from scammers, from insecure smart products, and from unsafe products – including this year a number of ‘health’ products making misleading claims about Covid-19 prevention. This year to increase our impact on scams we established a powerful consortium of 17 highprofile businesses to support our call for better legislation and business accountability for keeping consumers safe when they go online. We also raised the profile of our scams alert service. After promotional activity our scams alert email is now reaching c300,000 consumers a week – and not only this but more than half of recipients (57%) say they share our scams advice with others, giving us an even bigger audience!

81% scams alert recipients surveyed said they felt more aware of how to reduce the risk of scam, more confident about spotting a scam, and/or more aware of what to do if they were scammed

Consumer rights

With many sectors facing ongoing, unprecedented pressure, consumers are too often sharing that burden and we have repeatedly seen businesses use the pandemic as an excuse to breach consumer law. Particularly hard-hit areas included travel and wedding refunds issues. To add to an already busy year, multiple trade conversations post-Brexit also gave Which? a lot to consider as we scoured the deals on the table for potential consumer harm.

Travel challenges

The impact on travel as a result of the pandemic has continued into another year. We have made strong progress in tackling consumer harm over the past 12 months and we have delivered significant positive impacts for millions of consumers. We’ve been influencing key policy makers and provided relevant and responsive advice. Our investigations and subsequent submissions to the Competition and Markets Authority on cancellations led to it ordering some of the UK’s largest travel companies, including Loveholidays, Teletext and Lastminute.com to return hundreds of millions of pounds of withheld and delayed refunds to consumers.




Our influence in the travel sector was reflected by us being the only large consumer organisation invited by government to participate in the Global Travel Taskforce. Here we successfully defended efforts by airlines and holiday companies to amend and weaken key parts of consumer rights protection around cancellations, refunds, delays and package holidays, as well as feeding in consumer views on how travel should restart.

Did you know?

Travel editor Rory Boland was our most prominent spokesperson this year. He made 853 appearances as our primary travel spokesperson and was widely quoted in the national press, giving advice to consumers on travel restrictions, travel insurance and refunds.

WIN! More power to the CAA and consumers

We have found airlines regularly breaking the law over delay compensation, vouchers and refusing to help passengers get home when they cancel a flight. No airline in the UK has been fined or punished for breaking consumer law in 17 years, since the Civil Aviation Authority (CAA) gained its current powers. The government, having reviewed our evidence, committed to reform the enforcement powers that the CAA has on airlines that breach consumer rights.


We’ve seen text and email scams run riot as fraudsters have taken advantage of the confusion generated by the pandemic. Across the UK, people have lost £1.7 billion to scams in the last year (source: Action Fraud, Feb 2021). This has meant Which? has had much to do in fighting the seemingly neverending wave of scam threats by giving consumers the knowledge to spot and avoid them, or what to do if they have been affected by one.

From fraud victim to anti-scam campaigner

When Maria Teresa Jackson, 63, realised that she had lost over £120,000 of her retirement savings to a fraudster, she was in a complete state of shock. She had been groomed over a number of weeks, after clicking on a cryptocurrency investment advertisement that she had seen on a social media website. Given that the investment platform appeared to be endorsed by celebrity Bear Grylls, and the placement of the advert was on a trusted social media platform, Maria Teresa had been lulled into a false sense of security. Unbeknownst to her, she had been transferring her retirement funds into a criminal’s bank account.

Which? research found that three in five people have received a scam delivery text in the last year.

So far the scam alert service has seen over 300,000 sign ups, with those registered receiving regular alerts straight to their inbox as Which? discovers them.

We received 1,600 scam reports in the first 20 days after launching the scams sharer tool.

Our scams sharer tool shows us what types of scams are the most common, with telephone (33%) and text messages (32%) the ones most regularly reported to us.

Digital life

The rapid migration of goods and services to online has brought many benefits to consumers, but it has also created some significant challenges and detriments. Reliable and fast connectivity is becoming increasingly important and services such as broadband need to show they can support our needs. We’ve also highlighted areas that present real consumer harm, such as fake reviews. We’ve seen everyday items from kettles to toys go online, but the security and lifespan of these products can all too often leave a lot to be desired. Which? has ramped up our focus in this area to ensure consumer rights and safety are protected, be it in physical or digital spaces.


The battle against fake reviews continues

In June 2021, following on from a number of Which? investigations into fake reviews, the Competition and Markets Authority announced that it is investigating Amazon and Google over concerns that they have not been doing enough to combat this issue on their sites.


The pressures of the pandemic have caused even more bank and ATM closures and cash payments being refused by many retailers, and has also spurred on an increasing popularity of buy now, pay later consumer borrowing that leaves customers prey to an unregulated industry and at risk of borrowing what they can’t afford. Which? has often had to react quickly to the changing consumer trends, as well as continuing our work on longer-term goals such as influencing the Pension Schemes Bill.


Access to cash

Our campaign on access to cash has continued in 2020/21. We’ve worked hard to pressure the government, regulators and businesses to take stock of the issue and to act.

Cash Summit

We held our Cash Summit, a virtual event to which we invited major figures from the payments industry. The event featured speeches from the Financial Conduct Authority and HM Treasury and panels with major banks, digital payment companies and the Bank of England.

When the government published its consultation on cash legislation, it included proposals to make the Financial Conduct Authority the single regulator for the cash system – which was our main policy ask. Additionally, it outlines plans for geographic access requirements to be flexible and to deliver a range of solutions to ensure people can withdraw cash.

Increasing the relevance of our expert advice and content

Our expert reviews and advice are two of the ways we deliver our purpose, and the revenue for our paid-for content helps to fund the charitable work we do on behalf of all UK consumers. This year we’ve expanded our expert product reviews and endorsements to ensure we’re keeping up with consumer trends and demands.


How we reacted to changing consumer habits

With people stuck at home during the numerous lockdowns, we saw a shift in shopping habits, what products proved most popular and so we responded to provide relevant and timely information.

• We added 41 new categories of gardening recommendations to the Which? website and the Which? Facebook gardening group swelled to 11,600 members.

• Our health content reached an audience of more than six million (2019/20: 1.5m).

• Our travel content reached more than seven million people, up from one million in 2018/19.

• Our first Black Friday working from home was a resounding success, with organic sessions on our website up 406% from last year.


More than 85% of readers of our Travel magazine say they are likely to continue their subscription next year, reflecting the expert advice we’ve given during a year of travel uncertainty.

“I have been a member of the Consumers’ Association (Which?) since issue number two of the magazine and have every intention of remaining a member. I am a widower aged 96 looking after myself at home; I look forward to each issue with pleasurable anticipation.”

The services we provide


Evolving our subscription model

Despite the uncertainty brought about by the pandemic, Which? has continued to be brave in making changes to our membership model to ensure our long-term success. While successful at driving high volumes of new members, our previous membership offering – which was in place for 10 years – saw very high cancellation rates in the first year. Over the past five years new membership volumes have been unable to offset the underlying cancellation rates, so our paid membership has been in decline.

As part of our three-year strategy to drive growth, we have transformed our offering to deliver value over volume.

In September 2020, we successfully launched our new membership model – for the first time offering a choice of memberships, including a more affordable digital package and the re-introduction of annual payment options. So far, the numbers are looking very positive, with the retention of members who have joined through the new membership packages at an all-time high, and we have seen a 50% reduction in monthly cancellation rates in 2020/21: 2.64% (2019/20: 5.30%). This also helps us have more impact for consumers and supports our ambition to help a larger and more diverse range of consumers going forward.

Advice services

Tech, Legal and Money services have played a critical role in advising members on issues that have been drawn into sharp focus through the year, for example, advising those who are less tech-savvy on how to set up a video call. In fact, our Tech Support teams took 21,535 calls and received 7,238 emails.


Looking ahead

With the changes we’ve made to our membership offering and as we look to broaden our appeal to new audiences – which includes a drive to encourage more sign-ups from a more diverse consumer base – we expect to see a growth in membership. This will be supported by our new digital proposition to improve the member experience of our content.

Evolving Which? systems

Our three-year vision includes our commitment to transform systems that manage relationships with members and audiences. Which? will be able to use these systems to enhance the way in which members experience our content. For example, we will be able to directly share specific relevant offers and products to those who are most likely to need them and when they are most likely to need them, based upon their interactions with us and the activities of similar customers. This means Which? can deliver a member- and customer-led experience.

A key phase of the digital transformation includes delivering a new customer database and payment management system. It will also include self-service capabilities, enabling members to update their details or subscription online as well as over the phone.

We have faced some challenges in meeting our schedule and objectives on this important project. While we have delivered some aspects, we have not made as much progress as we had planned, including migrating the organisation to a singlecustomer management system. We are redoubling our efforts in this area and we are confident that we are now making important progress and will start to see the benefits across the organisation in the year ahead.

Reserves, risk and compliance

Reserves policy The Council of Trustees’ policy is to annually review the Group’s reserve levels to ensure they are sufficient:

• Ensuring there is sufficient working capital across the Group;

• Providing some protection against potential risks that could impact the organisation; and

• Offering some flexibility should investment need to be made within the business.

All our reserves are unrestricted, with no material amounts designated for specific purposes in future years. The Council of Trustees anticipates that reserves might be used to fund the Group objectives and the commercial business. Where reserves are used to fund the commercial business, this is expected to benefit the charity’s funding in the medium to long term and also contribute to making consumers’ lives simpler, fairer and safer.

Group balance sheet and reserves

Total Group reserves increased by £7.3m to £59.7m at June 2021, reflecting £4.9m of net incoming resources from trading activities (after accounting for £23.5m of expenditure on our charitable activities). Key points to note from the balance sheet include:

The £1.2m increase in intangible assets reflects our continual investment to improve our digital platforms after taking into consideration depreciation.

Year-on-year decrease of £1.6m in tangible assets largely reflects the depreciation of our Marylebone Road longleasehold premises and fixtures, fittings and equipment across our sites. A proportion of the property of Marylebone Road has been reclassified as an investment property as we leased the ground floor to a third party during the year.


The investment fund increased by £5.2m during the year, with the contributing factor largely being an increase in unrealised gains due to the recovery of the market.

All cash balances were held with Barclays, and this year we additionally placed £2m in a Barclays green deposit account.

• Creditors due after more than one year fell by £1.3m due to the continued repayment of the mortgage balance on Marylebone Road.

• The defined benefit pension liability is recognised at £9.6m (2019/20: £9.9m). Cash contributions of £2.2m improved the deficit and limited the loss in the year.

How we are run

The charity

The Consumers’ Association is the parent of the Which? Group. It is established as a company limited by guarantee (no. 00580128) and a registered charity (no. 296072). The Consumers’ Association is governed by its Council of Trustees and wholly owns the trading company Which? Limited.


The commercial subsidiary

Which? Limited is a registered company (no. 00677665) and generates the income for the Group to enable it to provide its many products and services to, and deliver impact for and with, UK consumers. 

The Which? Limited Board (the Board) sets and oversees the commercial direction of Which? Limited within the context of the Group strategy, vision and values, with the aim of delivering a long-term sustainable financial return for the charity. The Board, which is appointed by the Consumers’ Association, is chaired by Judy Gibbons and consists of four other independent non-executive directors and Anabel, our CEO.


Which? Limited owns a small financial services company, Which? Financial Services Limited (no. 07239342), regulated by the Financial Conduct Authority, and Which? Legal Limited (no. 08109992), which remains dormant.

Consumers and members

UK consumers are our beneficiaries and we’re here to tackle consumer harm by making life simpler, fairer and safer for them. It’s our members who fund the vital work we do for UK consumers. Most of our income comes from subscriptions – we receive no money from government, public donations, or other fundraising income. Members receive access to dedicated content and advice, and also have the opportunity to get more involved in the organisation by becoming ordinary members, which gives them more say in how we’re run – by taking part in our Annual General Meeting (AGM), at which they take highlevel decisions relating to our governance.

Our employees

Colleague wellbeing has been a key concern over the last year as the weight of consistent home working, lack of in-person interaction and general anxieties regarding physical and mental health were felt. We have continued to listen to and learn from our colleagues and provide support through a number of wellbeing and development initiatives.


Hybrid working and the future of the Which? offices

Our colleagues have faced their first full year of remote working and we’ve also onboarded more than 150 new starters remotely. We have continued to listen to and learn from our employees and provide support through a number of wellbeing and development initiatives. We’re planning a move to hybrid working later in the year (subject to any changes in government advice) and will be approaching this on a test and learn basis as we reopen our offices.

One certainty will be the need for less office space, and so we made the difficult decision to close our Bristol office, as well as lease out the ground floor of our London office. Colleagues at Bristol will be relocated to our existing Cardiff location for the days they are in the office.



A great place to work It’s important to Which? that current and prospective employees see Which? as a great place to work. This means we have the pick of the best and brightest to join our teams. In May 2021 we were named as a winner in the Public Relations and Communications Association Workplace Champion awards, which recognises teams that go the extra mile to establish positive and inclusive working environments for colleagues.

Internally, we look to recognise colleagues who go above and beyond or demonstrate they share Which?’s values. At the end of the year we give out a Values Sharer of the Year award, with the winner receiving a £1,000 contribution towards a learning opportunity of their choice.

“To be granted the Values Sharer award is an honour and a privilege – being recognised for your character and hard work feels very humbling. It’s a great initiative to be able to celebrate those living their values for the support of others.”

Conor Bannister, Values Sharer of the Year award winner 2020.

Council of Trustees Responsibility Statement

The Council of Trustees is responsible for preparing the Council of Trustees’ report (incorporating Strategic report) and the financial statements in accordance with applicable laws and regulations. Company law requires the Council of Trustees to prepare financial statements for each accounting period. Under that law, the Council of Trustees has prepared the financial statements in accordance with the United Kingdom Financial Reporting Standard, comprising FRS 102 ‘The Financial Reporting Standard applicable in the UK and Republic of Ireland, and applicable law (United Kingdom Generally Accepted Accounting Practice)’. Under company law, the Council of Trustees must not approve the financial statements unless it is satisfied that they give a true and fair view of both the Consumers’ Association and the Group and of the incoming resources and application of resources including the income and expenditure of the Group for that year.