The commission is awaiting ministerial approval for the increase in the threshold from £100,000 to £250,000, which would cover an extra 12,000 charities. But the ACIE said that any move to a higher threshold should be delayed until there is more guidance and regulation available.
The association's comments were prompted by a report from Sheffield Hallam University showing that funders, accountants and independent examiners had "serious concerns" about R&P accounts and wanted all charities to move on to Sorp-based accounts, currently used by larger charities.
"Too many charities are able to deliberately or accidentally distort the appearance of their accounts," said Fiona Gordon, chief executive of ACIE.
A Charity Commission spokeswoman said: "We recognise differing views exist, but there was a small majority in favour of an increase in the threshold. For many charities, the opportunity to produce accounts in a simpler, less expensive format will be welcomed."