This guide explains trustees’ fundraising duties in plain English, based on Charity Commission guidance (CC20) and the Code of Fundraising Practice. It’s a guide to help boards strengthen oversight without slowing delivery.
Trustee Fundraising Duties
Trustees are responsible for fundraising, even when the day-to-day work is delegated to staff, volunteers, agencies, or partners. A board does not need to approve every appeal, email, or event. It does need to set expectations, make sure risks are controlled, and be able to show it acted in the charity’s best interests.
A good trustee approach to fundraising does three things:
- protects the charity’s purpose, reputation, and resources
- protects the public, including people in vulnerable circumstances
- helps fundraising perform well by making priorities and guardrails clear
This is not legal advice. It is a practical guide to good governance.
What CC20 is (a guide to trustee fundraising duties)
CC20 is Charity Commission guidance on trustees’ duties in relation to fundraising. It applies to charities in England and Wales.
In plain English, it expects trustees to take responsibility for fundraising by making sure the charity:
- complies with the law
- fundraises only for the charity’s purposes
- uses funds for the purposes they were raised for
- manages resources responsibly
- is open and accountable
- acts with reasonable care and skill and in the charity’s best interests
- registers with the Fundraising Regulator and follows the Code of Fundraising Practice (recommended good practice)[1]
Trustee responsibility vs operational responsibility
Fundraising governance works best when responsibilities are explicit.
| Trustee-level oversight (governance) | Operational responsibility (delivery) |
|---|---|
| Agree fundraising ambition, priorities, and what success looks like | Plan activity, deliver campaigns, and manage day-to-day performance |
| Set guardrails: ethics, risk appetite, tone, and what is off-limits | Apply guardrails in practice and escalate when risk rises |
| Approve the overall fundraising plan and budget, and review performance | Manage budgets within agreed limits and report variances |
| Make sure controls exist: complaints, data protection, financial controls, and due diligence | Operate those controls and keep records |
| Ensure learning happens after incidents and complaints | Log issues, implement improvements, and train fundraisers |
The trustees’ duties (CC20 in practice)
Use this as a standing agenda and assurance checklist. Trustees should be able to answer these questions clearly, and minute the decisions that matter.
1) Purpose: are we fundraising for the right thing?
- Can we explain, in one sentence, how fundraising supports our charitable purposes?
- Are we clear which funds are restricted to specific purposes, and which are unrestricted?
- If we are raising funds for a specific project, is our appeal wording clear enough to avoid creating an unintended restriction? (See full guidance).
2) Plan and budget: do we have a credible fundraising plan?
CC20 expects trustees to plan fundraising effectively. A plan can be simple, but it should cover:
- what funds you need to achieve the impact you want
- methods you will use (and any you will not)
- the values that influence your approach and fundraisers’ conduct
- budget and other resources (people, volunteers, suppliers)
- how you will monitor performance, compliance, and cash handling[1]
Trustee prompts
- Are targets realistic, and do they match capacity?
- If income is below plan, what will we stop, delay, or scale back?
- If income exceeds plan, what controls kick in to manage higher risk (cash handling, reporting requirements, reputational scrutiny)?
3) Risk: have we identified and managed fundraising risks?
Trustees should ensure there is identification and management of fundraising risks. That includes:
- reputational risk (how fundraising could be perceived)
- financial risk (fraud, cash handling, restricted funds)
- data risk (GDPR, consent, suppliers)
- safeguarding risk (how fundraisers interact with the public)
- delivery risk (fundraising demands outstripping operational capacity)
Trustee prompts
- What are the top five fundraising risks this year?
- What is the early warning signal for each one?
- What is the escalation route if something goes wrong?
4) People and conduct: do fundraisers have the training and boundaries they need?
Trustees remain accountable even when fundraising is delegated. CC20 expects trustees to make sure fundraisers can fundraise safely, comply with the law, follow the Code, and follow charity policies.[1]
The Code of Fundraising Practice sets standards for trustees and governing bodies, including acting reasonably and carefully, managing risks, and having effective complaints handling.[2]
Trustee prompts
- Do we have a clear code of conduct for fundraising (staff, volunteers, suppliers)?
- Do people know what to do if a member of the public is upset, confused, or in vulnerable circumstances?
- Do we protect fundraisers from harm and harassment, and do they have a way to report issues?[2]
5) Complaints: can we respond quickly and learn properly?
The Code requires a clear, publicly available fundraising complaints procedure, and expects complaints to be investigated fairly, handled without unnecessary delay, and used for learning.[2]
CC20 expects larger charities to include information on complaints and what they do to protect the public from undue pressure, and encourages transparency more widely.[1]
Trustee prompts
- Do we review complaints as a board at least quarterly (even if there are none)?
- Do we know when a fundraising issue becomes a serious incident?
- Can we show what we changed as a result of learning?
6) Partners and suppliers: are we in control when others fundraise for us?
CC20 includes specific expectations when working with professional fundraisers and commercial participators. It expects trustees to:
- carry out proportionate due diligence
- make decisions in the charity’s best interests
- agree reasonable fees or a reasonable share of proceeds
- ensure required solicitation statements are made
- monitor agreements and manage subcontracting risks[1]
Trustee prompts
- Have we checked track record, methods, and alignment with our values?
- Can we explain, in plain English, what the charity receives and what others receive?
- Do we have a monitoring routine (spot checks, reporting, complaints, compliance)?
Quick decision tool: trustees’ duties to check fundraising
Use this table to sense-check planned activity and guide trustee discussions to meet their duties around fundraising.
| Do | Don’t | Trustee check |
|---|---|---|
| Be clear how fundraising supports your charitable purposes | Run fundraising that is only loosely linked to your objects | Can we state the purpose link in one sentence and minute it? |
| Set a fundraising plan and budget that matches capacity | Approve targets without a credible delivery plan and resourcing | What will we stop or de-prioritise if income is below plan? |
| Protect people and avoid undue pressure | Allow tactics that rely on guilt, confusion, or persistence | How do we handle people in vulnerable circumstances and complaints? |
| Use due diligence before appointing agencies or partners | Assume a contract alone reduces risk | What evidence do we have that they follow the Code and our policies? |
| Make sure restricted funds are tracked and used correctly | Create accidental restricted funds through sloppy appeal wording | Have we checked the wording and the finance process behind it? |
| Review complaints and incidents and change practice | Treat complaints as a comms issue only | What did we learn, and what changed? |
A practical board agenda: what to review, and how often
Use this to keep fundraising governance light but real.
- Every meeting (10 minutes): performance snapshot, risks, and any complaints
- Quarterly: fundraising plan performance, pipeline health, compliance checks, and learning
- Annually: approve fundraising plan and budget, review risk appetite, and review supplier arrangements
Sources
- Charity Commission for England and Wales: Charity fundraising: a guide to trustee duties (CC20)
- Fundraising Regulator: Code of Fundraising Practice
Meeting your fundraising duties as trustees
If you want to strengthen your fundraising governance, start with one simple move: add fundraising to your standing board agenda, and use the checklist above to structure a short quarterly review.
If you would like additional support, see our Charity Consultancy Services; our fundraising and income generation support services and our governance and assurance support services.