One of its founders Luke FitzHerbert said: "Like the first draft, the new draft is a bit of a mess. It is trying to do something that charities are already required to do. In our view, the summary of the annual report would achieve the proposed purposes of the SIR."
The first draft was slated by charities for being simplistic and using too much jargon (Third Sector, 14 May), but FitzHerbert claims that the Charity Commission has still not ironed out these problems.
"The SIR still contains too much fashionable jargon about targets and outcomes, which would be difficult for the public to understand. The original questions, which produced data responses, were described as meaningless.
However the questions are now so vacuous, there is almost nothing in them to react to," said Fitzherbert.
He said the SIR overlooked important information about how charities carry out their objectives. "Would the SIR distinguish between two charities with the same objective, one which employed its own staff, and one which only gave grants to other charities? The distinction is important, but their SIR returns could be identical."
The commission and the NCVO commissioned research on the effectiveness and usefulness of the first draft. A spokesman for the NCVO said: "The initial document was useful to regulators and to funders, but did not meet the Strategy Unit's criteria that it should be accessible to the public."
The SIR can be read on the Charity Commission's website and is being piloted by 200 charities.