The Charity Commission has refreshed its guidance for trustees on fundraising responsibilities (CC20) and emergency appeals (CC40). The aim is simple: help trustees understand what “good” looks like, especially at a time when many charities are working harder to secure donations while demand for services keeps rising.
Estimated reading time: 5 minutes
If you sit on a charity board, this matters because fundraising is not “the fundraising team’s job” in the eyes of the regulator. Trustees have ultimate responsibility for how the charity raises money, who it works with, how it communicates with the public, and how it manages the risks that come with fundraising.
Below is a practical, board-friendly summary of the key messages, plus a checklist you can use at your next trustee meeting.
Why the Commission updated the guidance
The Commission says the revised guidance is designed to be more concise and accessible, and to complement the Fundraising Regulator’s role and the Code of Fundraising Practice. In their blog post announcing the update, they note:
- The public’s generosity accounts for almost a third of charity income through donations and legacies, valued at £31.4bn in 2023.
- Over the past five years, fewer people have been donating or fundraising, which means many charities will need to work harder to attract and retain support.
One clear implication for trustees is that strong governance is not a “nice to have”. It is part of protecting public trust, reducing risk, and sustaining income.
What the Trustee fundraising responsibilities guidance focuses on
The Commission highlights three main areas in CC20:
- Planning fundraising
- Supervising fundraisers
- What to include in fundraising material
In practice, those headings map neatly onto a board’s core responsibilities: agree the plan, oversee delivery, and make sure the charity is honest and clear with the public.
1) Planning fundraising: the board’s job is to set direction and boundaries
Fundraising planning is not just about targets. Trustees should be confident that fundraising activity aligns with:
- The charity’s purposes and strategy
- The values the charity wants to be known for
- The capacity available (people, systems, budget, and time)
- The charity’s risk appetite
If your charity is under pressure to “bring in more money”, it can be tempting to chase quick wins or try every possible channel. Good governance means being more selective.
A practical approach is to ask management for a fundraising plan that sets out:
- The methods the charity will use, and the methods it will not use
- How success will be measured, not just in pounds raised, but in sustainability and donor experience
- The resources required, including hidden workload such as supporter care, finance processes, and data management
- The key risks and how they will be managed
2) Supervising fundraisers: delegation is fine, abdication is not
Most boards delegate fundraising activity to staff, volunteers, or third-party suppliers. The Commission’s message is that trustees still need to ensure proper oversight.
In practice, that means trustees should be able to answer these questions:
- Who is responsible for day-to-day fundraising delivery?
- What information does the board receive to monitor performance and risk?
- If third-party fundraisers are used, what due diligence was done?
- Do contracts clearly set expectations, reporting, and compliance requirements?
Oversight also includes culture. Trustees should encourage a fundraising culture that prioritises ethical practice and long-term relationships over short-term income at any cost.
3) Fundraising materials: be transparent and protect the charity’s reputation
Fundraising communications need to be truthful, clear, and not misleading. That includes what the charity says on websites, donation pages, social media appeals, and printed materials.
Trustees should be especially alert to:
- Clarity on what money will be used for, particularly where appeals are restricted to a specific purpose
- Avoiding ambiguous language that could create unrealistic expectations
- Making sure claims can be evidenced, including impact statements
This is not only about compliance. It is about maintaining the trust that income depends on.
Emergency appeals (CC40): “Can we do this?” comes before “Should we do this?”
The updated CC40 guidance is timely. In a crisis, the instinct to set up an appeal can be strong, and online platforms make it easy.
The Commission’s key reminder is that trustees should understand what their charity can and cannot do, and what the best way to help is.
Before launching an emergency appeal, trustees should check:
- Does the charity’s purpose allow this appeal? If not, raising funds could create regulatory and legal problems later.
- Can the charity deliver what it is promising? If the charity cannot provide relief directly, it may need to partner or signpost instead.
- What happens if more money is raised than expected, or delivery becomes impossible? This should be thought through in advance.
Trustee fundraising responsibilities checklist
A practical trustee checklist for your next board meeting. Use this as a 20-minute governance check-in:
- We have an up-to-date fundraising plan that links to our strategy and budget.
- Trustees understand the fundraising methods we use, and why.
- We know what laws and standards apply to our fundraising activity.
- We are registered with the Fundraising Regulator (where appropriate) and follow the Code of Fundraising Practice.
- We have clear reporting to the board on fundraising performance and risk.
- We have appropriate due diligence and contracts for any third-party fundraisers.
- Our fundraising materials are clear, accurate, and transparent about use of funds.
- Fundraising risk is reflected in our risk register, alongside fraud prevention and other organisational risks.
- We have a clear process for deciding whether to launch an emergency appeal, including purpose fit and delivery feasibility.
Where to get help
If your board wants confidence that fundraising is governed well, it can help to do a short “fundraising governance review” and translate guidance into a practical monitoring and assurance pack.
Sailfin supports trustees and senior leaders to strengthen governance, reduce fundraising risk, and build sustainable income for good. For more information, see: