In February 2026, the Charity Commission updated its guidance in relation to fundraising CC20: Charity fundraising – a guide to trustee duties. The revised guidance reminds all involved in charity governance that fundraising is a core responsibility, as opposed to a function that can be delegated and forgotten about.
Set against the backdrop of the Charities Act 2022 and the new Code of Fundraising Practice (which came into effect in November 2025), the updated guidance reinforces expectations around board oversight, risk management and accountability.
What does the updated guidance say?
At its core, it sets out what trustees must do to ensure fundraising is compliant, ethical and aligned with their charity’s purposes.
1. Trustees are ultimately accountable
The guidance’s message is clear. Trustees are responsible for all fundraising carried out in their charity’s name, even when those activities are delegated to staff, volunteers or third-party agencies. The key point here is that delegation does not absolve a trustee of accountability. Boards must maintain active oversight, ensuring that all fundraising activity meets legal requirements and reflects the charity’s values.
2. Stronger emphasis on board oversight
Noticeably, the guidance places more responsibility on the board’s role in supervising fundraising activity and avoiding over-reliance on delegation.
Trustees are expected to:
- Set fundraising strategy and direction
- Monitor delivery and performance
- Ensure appropriate controls are in place
- Challenge and scrutinise fundraising decisions
This reflects a shift from passive governance to active stewardship of fundraising practices.
3. Integration with the Code of Fundraising Practice
Trustees are explicitly directed by CC20 to follow the Code of Fundraising Practice and, where appropriate, register with the Fundraising Regulator.
The Code sets sector-wide standards, covering:
- Fundraising conduct
- Donor communications
- Use of third parties
- Protection of vulnerable individuals
The 2025 version of the Code is principles-based, meaning trustees must be able to show that decisions are “appropriate, reasonable and proportionate”, rather than simply going through a tick-box exercise for compliance requirements.
4. Focus on risk, reputation and public trust
One of the key themes is the link between fundraising and reputation. Trustees must ensure that they actively manage:
- Financial risks
- Legal compliance risks
- Reputational risks arising from campaigns or messaging
The Commission places a heavy emphasis to the risk of causing damage to public trust that poor fundraising practices can do. Governance in this area therefore becomes critical to protect and avert wider adverse impacts that may be attributable to the charity.
5. Core principles trustees must follow
The updated guidance is structured around six overarching principles:
- Plan effectively: Set clear strategies, identify what is needed and establish how – and by when – funds will be raised while considering risks and costs.
- Supervise fundraisers: Oversee everyone involved in your fundraising activities (including staff, volunteers and commercial partners) to ensure they follow your charity’s values.
- Protect your charity’s reputation, money and other assets: Identify and mitigate risks to donor data, charitable funds and the public image of your charity.
- Comply with fundraising laws: Ensure all fundraising activities adhere to relevant statutory legislation.
- Follow recognised standards: Align your operations with the Fundraising Regulator Code of Fundraising Practice.
- Be open and accountable: Communicate transparently with donors, supporters and the general public about how funds are raised and used
What this means for charities
The updated guidance, combined with the Code of Fundraising Practice, represents a big change in expectations.
1. Governance, not just compliance
Fundraising compliance can no longer sit just with fundraising teams. Instead, boards must show ownership of key decisions, including:
- Why a particular fundraising method was chosen
- Whether it aligns with the charity’s values and risk appetite
- How risks were assessed and mitigated
This reflects the Code’s move to principles-based regulation, and means that evidence of good decision-making is essential.
2. Greater scrutiny of delegation
Many charities rely heavily on third-party fundraisers or agencies. Under the updated guidance, this is acceptable, but trustees must:
- Conduct due diligence
- Monitor performance and compliance
- Ensure contracts and controls are robust
Regulators have made clear that outsourcing activity does not outsource responsibility.
3. Increased documentation and evidence
Trustees must now be able to evidence governance decisions, particularly if fundraising activity is subject to challenge.
In practice, this means:
- Recording decisions in board minutes
- Maintaining clear policies
- Documenting risk assessments and approvals
If investigated, regulators will ask why decisions were made, not just whether rules were followed. Trustees should be prepared for this.
4. Alignment with organisational values
A recurring theme in the updated guidance is that fundraising should reflect the charity’s purpose, values and identity.
This includes:
- Ethical messaging
- Honest representation of the effect
- Respectful engagement with donors
Fundraising now revolves around building and sustaining public trust rather than income.
Practical action points for compliance
To remain compliant with both the updated guidance and the Code of Fundraising Practice, charities should implement the following:
Governance and Oversight
- Ensure the board formally approves a fundraising strategy aligned with the charity’s purposes
- Schedule regular board-level reviews of fundraising performance and risks
- Clearly define roles and responsibilities between trustees and operational teams
Policies and Procedures
- Update or introduce a fundraising policy reflecting both the new guidance and the 2025 Code
- Establish clear procedures for:
- Ethical fundraising practices
- Use of third-party fundraisers
- Complaints handling
- Ensure contracts with agencies include compliance and monitoring requirements
Risk management
- Conduct regular fundraising risk assessments, covering:
- Reputational risks
- Legal and regulatory risks
- Financial risks
- Define a clear risk appetite statement for fundraising activity
- Implement escalation processes for high-risk campaigns
Compliance with the Code of Fundraising Practice
Review all fundraising activity against the principles of the Code:
- Legal: Fundraising must meet the requirements of the law.
- Open: Fundraisers must be clear about their processes and willing to explain them when necessary.
- Honest: Fundraisers must act with integrity and must not mislead people when asking for donations.
- Respectful: Fundraisers must respect the people and places they interact with.
Ensure decision-making is:
- Documented
- Justified
- Proportionate
- Register with the Fundraising Regulator where appropriate
Monitoring and assurance
- Introduce internal reporting mechanisms for fundraising compliance
- Carry out periodic audits or reviews of fundraising activity
- Monitor third-party fundraisers through:
- Performance reports
- Spot checks
- Compliance reviews
Transparency and accountability
- Ensure fundraising communications are clear, accurate and not misleading
- Maintain an open approach with donors about:
- How funds will be used
- Any changes to fundraising appeals
- Include required disclosures in the trustees’ annual report
Training and culture
- Provide training for trustees and senior leaders on the updated guidance and the Code
- Embed a culture of ethical fundraising and accountability
- Ensure fundraising reflects the charity’s values and public commitments
