While there is no absolute requirement to spend money within a year,
there is a requirement to justify your reserves. Having big reserves
just because you didn't get around to spending it isn't going to sit
very well.

Yes, this is the case.

However, the Charities Commission is quite used to charities which are going through the same transition that we are.

They're also used to charities which have a very large level of reserves. My current employer managed to build up reserves of £20 million during the noughties (plus a few million more in local branch accounts). I'm doing my best to run that down. ;-)

Chris