Charity campaigning (Trustee guide) ~ Sailfin

A trustee’s guide to charity campaigning & political activity

Charities have the right to campaign on issues that matter to their beneficiaries. If you are a trustee looking for guidance on charity campaigning, the key is staying confident about the legal boundaries, and making sure campaigning supports your charitable purposes without drifting into party politics.

This guide sets out what counts as campaigning and political activity, what trustees are responsible for, and practical checks to help your charity to stay independent, lawful, and effective.

Estimated reading time: 14 minutes

At a glance: what trustees need to know

This charity trustee guide about campaigning helps trustees make quick, confident decisions and avoid the common compliance traps.

Key point	You can	You cannot
Campaign on issues	Campaign for changes that further your charitable purposes	Campaign for or against a political party’s electoral success
Influence policy	Respond to consultations, brief decision‑makers, and advocate for policy change	Support or oppose candidates, or ask people to vote a certain way
Comment publicly	Criticise policies based on evidence and beneficiary impact	Use party‑political framing, or attack politicians in a partisan way
Work with others	Partner with organisations on shared, charitable‑purpose goals	Co‑brand or align with party‑political campaigns
Be especially careful	Increase review and sign‑off during elections and for social posts	Assume intent protects you. Perception matters

Trustees should: ensure purpose alignment, proportionality, independence, lawful methods, and documented oversight.

What counts as campaigning and political activity

Campaigning

Campaigning means raising awareness and seeking support for a particular cause, issue, or change. For charities, it is most effective to clearly root campaigns in your charitable purposes, based on evidence and lived experience, and framed around the impact on beneficiaries. Campaigning can be public-facing, behind the scenes, or both. It can ask for better services, changes in guidance, or improving how implementation of existing policy.

In practice, campaigning often includes:

Raising awareness of issues affecting your beneficiaries
Highlighting gaps in policy, services, or funding
Calling for specific changes to law, policy, or practice
Mobilising public support for your cause
Engaging with decision-makers and stakeholders

Campaigning is a legitimate activity for charities when it furthers your charitable purposes.

Political activity

Political activity means attempting to influence government, public authorities, or political parties on matters of policy or legislation. It is often a natural extension of campaigning, especially where the change you want requires government action. The key is to focus on issues, not parties, and to make sure your approach is balanced, proportionate, and consistent with your charity’s independence.

Examples include:

Responding to government consultations
Meeting with MPs, councillors, or civil servants
Briefing political parties on issues linked to your charitable purposes
Commenting on proposed or existing legislation
Advocating for policy changes

Political activity is also legitimate for charities, provided it supports your charitable purposes and you remain independent of party politics.

What is not allowed

Charities cannot engage in party political activity. It is not enough to avoid explicitly endorsing a party. Trustees also need to avoid activity that could reasonably be interpreted as partisan, especially during election periods or when working with high-profile partners.

Not allowed	What this can look like in practice	How to stay on the right side
Supporting or opposing a political party	Statements, calls to action, or partnerships that could reasonably be read as backing a party	Keep messaging issue-led, avoid party branding, and apply a perception check before publishing
Supporting or opposing a candidate	Endorsing candidates, asking people to vote for someone, or campaigning against an individual standing for election	Avoid candidate-focused content. If engaging locally, do so in a balanced way and document why
Aligning your charity with a party	Co-branding, jointly organised events, or language that makes you look like part of a party campaign	Be cautious with joint activity. Keep governance clear, and separate the charity’s voice from party campaigning
Giving the impression of endorsement	Wording, imagery, timing, or social posts that look like taking sides, even without explicit support	Stress-test how it could be shared out of context, and increase review/sign-off during election periods

This is a fundamental principle of charity law and applies at all times, not just during election periods.

The legal framework

Charity campaigning: trustee guide to responsibilities and practical checks

Trustees need the core legal principles, plus practical governance checks that help boards make confident, compliant decisions. The aim is not to slow campaigning down. It is to make sure your charity can show clear purpose, independence, and appropriate oversight if you are challenged.

Charity law principles

Charity law allows campaigning and political activity when it is clearly linked to your charitable purposes, in your charity’s best interests, lawful, and independent of party politics. Trustees should be able to explain the purpose link, and show that decisions were made reasonably, proportionately, and with an eye on reputation and risk.

Trustee responsibilities

Trustees are legally responsible for ensuring proper governance for charity campaigning. In practice, the guidance means being able to show five things:

Trustee responsibility	Plain English check
Clear link to your charitable purposes	Can we explain, in one sentence, how this furthers our objects?
Proportionate use of resources	Is the time, money, and reputational risk justified by the likely benefit to beneficiaries?
Independence and reputation protection	Is this clearly issue-led (not partisan), and would it still read that way if shared out of context?
Lawful and appropriate methods	Are the methods legal, respectful, and consistent with charity law and wider obligations?
Proper risk assessment and oversight	Have we agreed sign-off routes, recorded the rationale, and kept an evidence trail for significant activity?

The Charity Commission’s role

In England and Wales, trustees are accountable to the Charity Commission as the sector regulator. In the context of campaigning, it is helpful to understand what the Commission is there to do, and what it will consider if concerns are raised. The Charity Commission’s role is:

Publishing guidance on campaigning and political activity
Assessing concerns raised about charities
Take regulatory action where charity law has been breached
Protecting the legitimate right of charities to campaign

The Commission has said it takes a proportionate, risk-based approach to concerns about campaigning. See CC9 (Speaking out).

Staying independent: the party political line

Why independence matters

Trustees rarely set out to be party political. The risk is that campaigning can be interpreted that way by supporters, journalists, politicians, or regulators, particularly in a heated moment or during an election period. Independence is not only a legal requirement. It is also what makes your advocacy credible.

Maintaining independence is both a legal requirement and a practical necessity. If a charity appears aligned with a political party, the common impacts include:

Loss of public trust and support
Alienating beneficiaries and supporters
Increased regulatory scrutiny and legal risk
Undermining your advocacy and influence

Issues vs parties

You can campaign on issues. You cannot campaign for or against parties.

In practice, that means you can challenge a policy, but you cannot turn that into support for or opposition to a party. You can be robust on evidence and impact, but you need to keep your framing issue-led, not partisan.

Perception matters

It is not enough to avoid explicitly supporting or opposing a party. Trustees also need to avoid giving that impression.

Consider how someone could interpret your messaging:

Could a reasonable person see this as promoting or criticising a party?
Does the tone or framing read as partisan?
Could someone share or quote it in ways that make it appear party political?

If the answer to any of these is yes, revise your approach.

During election periods

Election periods require extra care. Political debate is heightened, media scrutiny increases, and the risk of misinterpretation grows. The safest approach is to increase review and keep a clear evidence trail for decisions.

During elections:

Increase review and sign-off for campaign materials, especially social content
Brief staff and volunteers on independence and how to handle pushback
Monitor and respond carefully on social media, with clear escalation routes
Avoid launching new activity that could reasonably be read as targeting parties

You can continue existing campaigns, respond to consultations, and comment on issues. Just take extra care to stay focused on issues rather than parties or candidates.

Planning and approving campaigns

This charity campaigning trustee guide is not a substitute for legal advice, but it will help you structure decisions, governance, and oversight in a way that stands up to scrutiny. The practical goal is simple: if trustees are asked why you campaigned, how you stayed independent, and how you managed risk, you can answer clearly and point to an appropriate decision trail.

Questions trustees should ask

Before approving any significant campaign, charity trustees should be able to answer a small set of core questions to help guide their operational teams. These help you stay focused on purpose, independence, and proportionality, rather than getting pulled into party political territory or approving activity without clarity on risk.

Trustees should satisfy themselves that:

Purpose: Does this campaign further our charitable purposes?
Resources: Is this a proportionate use of our resources?
Independence: Does this maintain our independence from party politics?
Effectiveness: Is this likely to achieve our intended impact?
Risk: What are the risks, and how will we manage them?
Methods: Are the methods lawful and appropriate?
Reputation: How will this affect our reputation and relationships?

If trustees cannot answer yes to all of these, the campaign should not proceed in its current form.

Delegating campaign decisions

Trustees can delegate day-to-day campaign decisions to staff, but delegation needs boundaries. Put clear decision rights and escalation routes/guidance in place so sensitive or high-profile charity campaign activity is reviewed at the right level, including by trustees where appropriate, and especially during election periods.

Trustees should:

Set clear policies on approvals at different levels
Ensure staff understand the legal framework
Require trustee approval for significant or sensitive campaigns
Monitor campaign activity and its impact
Review delegation arrangements regularly

Significant campaigns, particularly those involving political activity, should always have trustee oversight.

Documenting decisions

Good documentation does not mean bureaucracy. It means recording enough to show that trustees made a reasonable, informed decision and took risk seriously. For significant campaigning, trustees should document:

The rationale for campaign activities
How campaigns further charitable purposes
Risk assessments and mitigation plans
Budget and resource allocation
Monitoring and evaluation plans

This protects trustees, demonstrates good governance, and provides evidence that you acted appropriately if questions arise.

Social media and digital campaigning

Social media delivery is usually delegated to staff, freelancers, or agencies. Trustees do not need to approve every post. Trustees do need to make sure there is an appropriate policy, decision framework, and escalation route, so that high-risk content is reviewed at the right level and the charity stays independent.

Trustee-level oversight (governance)	Operational responsibility (delivery)
Agree an approach to independence, tone, and risk appetite	Draft and schedule content in line with that approach
Set sign-off rules (what needs senior or trustee review)	Run day-to-day sign-off and quality checks
Agree escalation routes for controversy, complaints, or media attention	Monitor channels and escalate early when risk rises
Review incidents and learning (especially during election periods)	Keep a simple log of issues, decisions, and removals/corrections

Particular risks

Social media creates specific risks for charities. A simple risk-register view can help to guide operational teams to manage charity campaigns consistently and know what to escalate to senior leadership or trustees.

Risk	What can go wrong	Controls (operational)	Escalate when
Speed and permanence	A post goes live quickly, is screenshotted, and is hard to retract even if corrected later	Pre-publish review for higher-risk posts; maintain a corrections approach (delete vs clarify); keep an approvals record for significant posts	The post relates to party politics, elections, a sensitive incident, or attracts media attention
Context collapse	Content intended for supporters is reshared without context and interpreted as partisan or misleading	Write for the “hostile screenshot” test; avoid in-jokes; make the purpose link explicit; include a neutral framing line where needed	The message is being shared outside your usual audience, or is being quoted out of context
Tone and framing	Informal or emotive language is read as party political, aggressive, or inaccurate	Use evidence-led wording; avoid party slogans; maintain a style guide for campaigning; run a perception check before publishing	The tone shifts into “attack” mode, or staff are uncertain whether it reads as partisan
Engagement and replies	Comments pull the charity into party political debate, or staff replies become inconsistent or confrontational	Set reply boundaries; use pre-agreed lines for election periods; define who can reply; moderate comments and escalate early	The thread becomes political, abusive, or high-traffic, or staff feel pressured to respond quickly
Visual content	Images or video are interpreted differently from the caption, or imply endorsement through people, locations, or symbols	Check visuals for party branding/symbols; avoid candidate-focused imagery; apply the same sign-off rules as copy	A visual includes politicians, party branding, polling stations, or election-related settings

When things go wrong

If someone complains (to you, to the Commission, or both)

Concerns about campaigning can come in different routes:

A complaint made directly to your charity (for example from a beneficiary, supporter, member of the public, or a political stakeholder)
A concern raised with the Charity Commission
Both routes at the same time, especially if the issue has attracted attention online

Responding to complaints made to your charity

If you receive a complaint directly, focus on getting the basics right quickly:

Acknowledge it promptly and explain when you will respond substantively
Check the facts, your evidence base, and how the activity furthers your charitable purposes
Apply an independence/perception check (how a reasonable person could interpret it)
Decide what changes to make (for example wording, timing, visuals, or moderation approach)
Document the decision and rationale (so trustees can evidence oversight if needed)

If the Charity Commission is contacted

The Charity Commission assesses concerns raised with it and will review activity against charity law. In practice, it will consider context, intent, and impact, and apply a proportionate, risk-based approach to determine next steps. See CC9 (Speaking out): https://www.gov.uk/government/publications/speaking-out-guidance-on-campaigning-and-political-activity-by-charities-cc9

If the Commission contacts you, be prepared to:

Provide a clear explanation of purpose, independence, and proportionality
Share relevant records (decision notes, risk assessment, approval route, and any corrections made)
Explain what you have learned and what you have changed (if anything)

Learning and improving

Use complaints and concerns as opportunities to:

Review your campaign governance
Strengthen staff briefings and policies
Improve approval processes
Build trustee understanding of the legal framework

Practical examples

What you can do

Campaign for policy changes: A homelessness charity campaigns for increased social housing investment, regardless of which party proposes it.

Criticise specific policies: A mental health charity raises concerns about proposed cuts to community mental health services.

Brief all parties: A disability charity shares evidence with all political parties about accessibility barriers.

Respond to consultations: An environmental charity submits detailed responses to government consultations on climate policy.

Use emotive language: A domestic abuse charity uses direct, powerful language about the impact of funding cuts on survivor safety.

What you cannot do

Endorse candidates: Telling people to vote for a candidate because they support your cause.
Attack party character: Describing a party as uncaring, corrupt, or dishonest.
Compare parties: Publishing a scorecard that ranks parties on their policies.
Align with campaigns: Joining a campaign that is organised by or closely associated with a political party.
Imply endorsement: Using language or imagery that suggests your charity supports a particular party.

Resources and guidance

The Charity Commission has published comprehensive guidance:

These are regularly updated resources and should be your first reference point when planning campaigns.

Quick decision tool: do, don’t, and trustee checks

Use this table to sense-check planned activity and guide trustee sign-off discussions.

Do	Don’t	Trustee check
Be clear how the activity furthers your charitable purposes	Run campaigning that is only loosely connected to your objects	Can we point to the purpose link in one sentence and minute it?
Use evidence and beneficiary impact to frame messages	Use party‑political language, slogans, or “vote for/against” implications	Would a reasonable person see this as issue-led rather than partisan?
Engage decision‑makers across parties where relevant	Give special access, endorsement, or co‑branding to one party or candidate	Are we visibly independent and balanced in who we engage?
Increase review and sign‑off during election periods	Assume “we didn’t mean it” will protect you if challenged	Have we applied an election-period checklist and recorded the decision?
Use social media carefully, with pre-agreed boundaries	Get drawn into partisan debates in comments or replies	Who is moderating, and what is the escalation route if it heats up?
Document rationale, risks, and mitigations for significant campaigns	Rely on informal agreement with no clear audit trail	If questioned, could we evidence proportionality and oversight?

Getting support with charity campaigns or trustee guidance

If you want a second pair of eyes before you publish, support is available.

Sailfin can help charities with governance and assurance support:

A trustee-friendly campaigning policy and approval process
Risk review of planned campaigns (including election-period checks)
Review of messaging and materials for independence and compliance
Briefings for trustees and senior leaders on the legal framework and practical decision-making
Understanding Trustee fundraising responsibilities

Get in touch to discuss what you are planning, and the level of support you need. Have a read of our useful primer article about charity governance support for trustees and boards. If you are looking for a charity campaigning trustee guide that is tailored to your charity, we can also provide a short trustee briefing and checklist.