Fundraising is about far more than generating income — it’s fundamentally about building and maintaining public trust. The Charity Commission’s refreshed CC20 guidance is a timely reminder that effective fundraising governance sits firmly with the board. It isn’t something that trustees can simply delegate and assume is being managed elsewhere.
Fundraising can seriously damage a charity’s reputation. A recent investigation by the Fundraising Regulator found that Stoke Air Ambulance CIO, a charity fundraising to establish an air ambulance service for the Stoke on Trent area, misled donors through online materials that implied it was already operating a functional service, despite having no aircraft, operational base, clinical staff, or regulatory approval. The regulator also identified unevidenced and unfairly critical claims about other air ambulance charities, as well as fundraising messages that encouraged donors to redirect payroll giving away from existing organisations. These breaches have prompted the Charity Commission to open a statutory inquiry, with regulators directing the charity to remove misleading statements, stop criticising other organisations, and contact donors to ensure they were not adversely influenced.
The updated CC20 sets out six key principles that trustees should follow when overseeing their charity’s fundraising activity. These include:
- taking clear responsibility at board level,
- ensuring fundraising plans align with organisational values
- providing proper oversight of everyone involved in fundraising — including external partners.
- safeguarding the charity’s reputation and assets
- complying with all relevant laws and recognised standards, and
- communicating openly and transparently with supporters and the wider public.
Importantly, the revised guidance incorporates changes brought in by the Charities Act 2022, offering more practical advice on issues such as failed appeals and what trustees should do when fundraising efforts don’t unfold as expected.
Overall, CC20 is a helpful prompt for Trustees, Chairs and senior leaders to reflect on whether their approach to fundraising is sufficiently robust, ethical and values driven. When was the last time your board paused to seriously consider fundraising risk and reputation? It’s well worth revisiting.
If you have any questions, please contact Sarah Williams [email protected] or Neil Burton [email protected]
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