Artificial intelligence is rapidly becoming part of everyday charity operations. From drafting fundraising materials and analysing donor data, to preparing board papers and supporting service delivery, AI is no longer confined to the IT team. The Charity digital skills report 2026 explains that most charities are now using AI in some form, with growing use in governance, policy drafting and compliance activities.
A governance challenge hiding in plain sight
One of the most interesting features of the current debate is that AI adoption is accelerating, but formal charity-specific regulation remains limited.
While the Charity Commission has written an article on AI and the opportunities and risks it presents, it isn’t planning to issue formal guidance equivalent to its established trustee guidance. As a result, charities largely need to navigate AI by applying existing trustee duties and governance principles.
What trustee duties are most relevant?
Acting in the charity's best interests
Trustees should consider both the opportunities and risks presented by AI.
Potential benefits include:
Increased efficiency
Better use of staff time
Improved access to information
Enhanced supporter engagement
These benefits must be weighed against the well-publicised risks of AI use.
Managing resources responsibly
Many charities are exploring AI because of growing demands and limited resources.
Trustees should ask:
Can AI improve the charity's effectiveness?
Have costs and benefits been properly evaluated?
Are appropriate controls in place?
Efficiency gains should not come at the expense of quality, accuracy or beneficiary welfare.
Exercising reasonable care and skill
AI can generate convincing but inaccurate outputs.
Fundraising materials, board papers, reports and policy documents prepared using AI should not be accepted uncritically.
Trustees and senior staff should ensure:
Appropriate human review
Verification of factual content
Clear accountability for outputs
The use of AI does not reduce a trustee's responsibility to exercise independent judgement.
Responsible AI: A question of values as well as governance
For charities, the conversation should not stop at compliance.
Boards may also wish to consider:
The environmental impact of AI and whether it is being used proportionately.
Risks of bias and discrimination in AI-assisted decision-making.
Accessibility and inclusion for beneficiaries, volunteers and staff.
Whether the charity's use of AI reflects its mission and values.
Alongside legal compliance, trustees should ask a broader question: does this use of AI support our charitable purposes and public benefit objectives?
Fundraising
The Fundraising Regulator’s guidance emphasises that charities remain fully responsible for any use of AI in fundraising and should approach it with appropriate governance, risk management and transparency. Trustees should be actively involved in decisions about AI. Organisations should:
Carry out proportionate risk assessments.
Adopt and regularly review an AI policy which is published on the charity’s website.
Ensure staff have the necessary skills and training; and test AI tools before implementing them.
Particular attention should be paid to data security, privacy and cyber risks. Seek legal advice where necessary.
When using AI, charities should:
Be transparent with donors.
Maintain meaningful human oversight of AI-generated content and decisions.
Keep records of checks and decisions where appropriate.
Ensure all AI-generated material is accurate, lawful and used in a way that protects both donor trust and the reputation of fundraising.
Refrain from feeding non-public information into publicly available AI tools without careful consideration.
What should boards do now?
Three practical steps:
Identify where AI is already being used across the organisation.
Ensure AI-related risks are included within the charity's risk management framework.
Review whether existing governance, technology and data protection policies adequately address AI use, as well as creating an AI policy.
AI may be new. Good governance is not. Until a more developed regulatory framework emerges, trustees will need to rely on familiar duties of care, stewardship, risk management and accountability to guide their organisation's approach.
If you have any questions please contact Sarah Williams.
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