Updated Code of Fundraising Practice 2025

It’s Tuesday morning in a small charity office in Manchester, and a fundraising manager stares at her inbox with growing concern. Three donor complaints about aggressive street fundraisers, two questions about data protection, and one worried trustee asking if their new online raffle is even legal.

Sound familiar? I’ve worked with charities across the UK for years, and I see this scenario play out constantly. The fundraising aspect keeps shifting, donors expect more transparency, regulations get tougher, and the pressure to bring in funds never lets up.

That’s where the Code of Fundraising Practice 2025 comes in. Think of it as your ethical compass for fundraising, a practical framework that protects your charity, respects your donors, and keeps you on the right side of the law. The Fundraising Regulator maintains this code, and it applies to fundraising across England, Wales, and Northern Ireland. If you’re a Scottish charity working in these areas, it covers you too.

Why Ethical Fundraising Matters More Than Ever

Let me be direct about this. Public trust in charities took a battering over the past decade, with high-profile scandals, stories of vulnerable donors being pressured, data breaches, and aggressive fundraising tactics. Each incident chips away at the goodwill that keeps the sector alive.

The 2025 Code addresses these concerns head-on by building on four core principles:

  • Legal – Your fundraising must meet legal requirements
  • Open – Be clear about your processes and willing to explain them
  • Honest – Act with integrity and don’t mislead people
  • Respectful – Respect the people and places you interact with

These aren’t just nice words on paper; they’re the foundation of sustainable fundraising. The latest version represents a significant shift towards principles-based regulation, giving charities the flexibility they need whilst maintaining high ethical standards.

What’s New in the 2025 Code of Fundraising Practice

This latest version represents a significant departure from the old prescriptive approach. The old code was full of specific rules and lists of what you could and couldn’t do in every situation. The 2025 version takes a principles-based approach instead, giving you principles to apply rather than rigid rules to follow.

Terms like “appropriate,” “reasonable,” and “proportionate” replace rigid rules throughout the document. This matters enormously because fundraising continues to evolve with new platforms, changing donor expectations, and advancing technology. A principles-based code adapts to these changes without needing constant updates.

The 2025 update also strengthens guidance on:

I’ll walk you through what this means for your day-to-day work, starting with the absolute basics.

What the Code of Fundraising Practice Is

The Code of Fundraising Practice sets the standards for ethical fundraising across the UK. It’s not law in the technical sense, but it outlines what the Fundraising Regulator expects from everyone involved in fundraising activities. That includes:

  • Registered charities
  • Community interest companies
  • Social enterprises
  • Professional fundraisers
  • Commercial partners
  • Volunteers
  • Third-party agencies

If you’re asking people for money or support for a charitable cause, this code applies to your work. Even if you’re not registered with the Fundraising Regulator, the code still covers your activities, and the regulator investigates complaints about fundraising whether you’re registered or not.

1. Why Your Charity Should Follow the Code

Code compliance isn’t just about ticking boxes or avoiding regulatory problems. It directly impacts your ability to raise funds sustainably and maintain the trust that keeps donors coming back.

When charities follow the Code consistently, they see tangible benefits. Complaint rates stay low because donors feel respected in every interaction. Retention improves because people trust how their money is being handled. Reputation strengthens because ethical practice becomes part of your organisation’s identity.

The opposite is also true. Poor fundraising practices damage your charity in ways that take years to repair. Aggressive tactics might bring in short-term income, but they erode the goodwill you need for long-term sustainability. One viral complaint on social media can undo months of deep relationship-building.

That’s the power of following the Code properly. It’s not bureaucracy for its own sake; it protects your reputation and builds lasting donor relationships that sustain your work for years to come.

2. Benefits of Principles-Based Fundraising Regulation

Here’s what I genuinely love about the principles-based approach in practice. It works equally well for tiny community groups and major national charities, recognising that a small volunteer-run organisation doesn’t need the same complex systems as a charity with 200 staff members.

“Appropriate” due diligence for a £100 cash donation looks completely different from due diligence on a £50,000 legacy. “Reasonable” steps to verify a donor’s capacity vary enormously based on the specific situation. This flexibility means you can apply the Code proportionately to your charity’s size and activities without drowning in unnecessary bureaucracy.

According to the Charity Commission, public trust in charities currently sits at around 6.7 out of 10, which represents an improvement from recent lows, partly thanks to better self-regulation through codes like this one. That trust is precious and worth protecting.

Major Changes in the 2025 Code of Fundraising Practice

Let me break down the major updates in the 2025 Code and explain what they mean for your actual fundraising practice.

1. How Principles-Based Flexibility Works in Practice

The old code might have stated flatly “You must not approach people in queues,” whilst the new code says “You must avoid approaching the public at unsuitable moments” and then provides examples, including people in queues. This seems like a subtle distinction, but it’s actually powerful because it requires you to use professional judgment.

If someone’s waiting at your charity’s promotional stand, approaching them is completely fine because they’re there specifically to engage with you. But hassling someone in the queue at Tesco is clearly inappropriate and disrespectful. This means you need to train staff and volunteers to understand the underlying principles, not just mechanically follow a checklist without thinking.

2. New Standards for Digital Fundraising

Digital giving absolutely exploded during the pandemic, and the 2025 Code finally catches up with this reality. New guidance covers:

  • Online fundraising platforms
  • Social media campaigns
  • Tap-to-donate devices
  • Digital consent and data protection requirements
  • Processing fees transparency

For example, if you use a platform that charges fees for hosting your campaign, you must make those fees crystal clear before donors provide their payment details. Not buried somewhere in lengthy terms and conditions that nobody reads, but clear and immediately visible on the donation page itself.

3. Protecting Vulnerable Donors Under the 2025 Code

This represents a huge shift in emphasis throughout the Code. The 2025 version now requires you to actively consider donors who may be in vulnerable circumstances, not just avoid obviously problematic situations. You must:

  • Not accept donations if you know someone can’t make an informed decision
  • Return donations if you discover the donor lacked capacity at the time they gave
  • Avoid asking under-18s for regular donations by direct debit
  • Take reasonable steps to identify vulnerability in your interactions

Here’s a practical example of how this works. An 85-year-old donor calls your office to set up a monthly donation of £100, but your fundraiser notices she seems confused about what she’s agreeing to, mentions she’s already supporting 7 other charities monthly, and sounds distressed during the conversation. Under the Code, your fundraiser must not proceed with that donation, even though you’d be losing £1,200 in annual income.

Yes, you lose the immediate income, but you protect someone vulnerable and maintain your charity’s integrity. That’s the trade-off ethical fundraising requires, and it’s the right trade-off to make every single time.

4. Holding Third Parties Accountable

Many charities work with professional fundraising agencies for call centres, street fundraising teams, and commercial partnerships. The 2025 Code is absolutely crystal clear about one thing: outsourcing fundraising doesn’t remove your responsibility for how it’s conducted.

You must conduct thorough due diligence before hiring any partners, have written agreements with appropriate protections built in, actively monitor that partners follow the Code requirements, and be able to end agreements quickly if standards slip. If your hired agency messes up, the Fundraising Regulator holds your charity accountable, not just the agency that did the actual work.

For example, your charity hires an agency for telephone fundraising campaigns. That agency must follow every requirement in the Code, and you need to monitor call recordings regularly, check complaint rates monthly, verify they’re not calling people registered on the Telephone Preference Service, and take immediate action if problems emerge. If they violate the Code, it’s your charity’s name in the investigation report.

5. Guidelines for Events, Raffles and Competitions

The updated Code provides much clearer guidance on:

  • Risk assessments for fundraising events
  • Health and safety responsibilities
  • Clear terms for competitions and raffles
  • Processing sponsorship money properly
  • Refund procedures if events are cancelled or participants can’t attend

Here’s a practical example. You’re organising a charity marathon where participants pay a £50 registration fee and commit to raising a minimum of £500 in sponsorship. Under the Code, you must clearly explain:

  • What the £50 registration fee covers
  • What happens if participants don’t raise the full £500
  • Whether any sponsorship money covers their personal costs
  • Exactly how refunds work if they can’t participate due to injury or other circumstances

This level of transparency prevents disputes before they happen and builds genuine trust with your supporters. Review all your third-party contracts, online donation processes, and event terms now to make sure they align with these updates before 1 November 2025, when the Code takes full effect.

Core Standards for All Fundraising

Every single fundraising activity must meet certain baseline standards, regardless of whether you’re running a street collection, sending marketing emails, or accepting online donations. Let me walk you through these fundamental requirements.

1. Building Fundraising on Ethical Behaviour

The Code requires fundraising that’s legal, open, honest, and respectful in every interaction. This sounds completely obvious, but I see violations constantly in my work with charities across the sector.

Respectful fundraising means:

  • Not intruding unreasonably on someone’s privacy
  • Accepting immediately when someone says no
  • Avoiding manipulative tactics made to create guilt
  • Not putting undue pressure on potential donors
  • Ending interactions quickly when asked

You must never:

  • Mislead donors by leaving out important information
  • Exaggerate details to encourage donations
  • Use guilt or shame as deliberate fundraising tactics
  • Claim donations will be used for specific purposes when they might not be
  • Take advantage of donors’ honest mistakes for your benefit

2. Governance and Trustee Responsibilities in Fundraising

Your trustees own fundraising outcomes and compliance, not just the fundraising manager or the CEO. The governing body carries ultimate responsibility, which means trustees must:

  • Take overall responsibility for all fundraising activities, including those carried out by partners
  • Assess and manage fundraising risks systematically
  • Ensure proper complaint handling procedures exist and work effectively
  • Make sure fundraising complies with data protection law
  • Protect fundraisers from harm and harassment whilst working
  • Respond constructively to enquiries from the Fundraising Regulator

Trustees are responsible for fundraising governance, whether they choose to engage with it or not. Practical steps trustees should take include:

  • Reviewing fundraising complaints quarterly in board meetings
  • Personally approving all major third-party contracts before they’re signed
  • Ensuring written policies exist for accepting and refusing donations
  • Monitoring key fundraising metrics beyond just income totals
  • Genuinely understanding the main fundraising methods being actively used

3. Processing Donations Properly and Securely

The Code contains detailed standards for handling different payment types safely. The overarching principle is simple: donations must be kept secure and processed with complete transparency.

For cash donations specifically, you must:

  • Count and record money without any delay
  • Never leave unsecured cash unattended in offices or vehicles
  • Bank cash as soon as reasonably possible
  • Keep cash in a proper safe until it’s banked
  • Ideally have two unrelated people present when counting. Someone who didn’t count the original cash should verify that the banking records match.

For collection boxes:

  • Label, number, and seal all boxes before distribution
  • Provide proper receipts when boxes are returned by collectors
  • Never take expenses from sealed boxes unless explicitly agreed beforehand
  • Maintain detailed records of all box numbers and their locations

For online and card payments:

  • Use appropriate security measures that meet current standards
  • Follow PCI-DSS requirements for handling card data
  • Make processing fees completely clear before asking for any payment details
  • Don’t issue refunds on card payments until those payments have fully cleared your account

4. Honest Communication with Donors

Your fundraising communications must be truthful and clear in every instance. This applies to:

  • Fundraising appeals
  • Websites and social media content
  • Letters and emails
  • Phone calls
  • Face-to-face conversations with potential supporters

You must:

  • Never mislead through deliberate omission or exaggeration
  • Have proper evidence for any claims you make in appeals
  • Explain clearly what happens if you raise more or less than the target amounts
  • Not claim to offer financial advice unless properly qualified
  • Treat all donors fairly, regardless of their giving level

Let me give you a clear “do and don’t” example that comes up constantly. Don’t say “Donate £50 to buy a wheelchair for Sarah” because you can’t guarantee that specific wheelchair goes to that specific child. You’re creating a restricted purpose that might not be achievable, and that’s misleading.

Do say “Your £50 donation could help provide wheelchairs for children like Sarah” or “£50 helps fund our wheelchair programme, supporting children like Sarah.” See the crucial difference? One creates a specific obligation you might not be able to meet, whilst the other is honest about how charitable donations actually work in practice.

Secondary purposes matter enormously for transparency. If you’re fundraising for something specific, you must explain what happens if you raise too much or too little. For example, “We’re raising £10,000 to repair our community centre roof. If we raise more than needed, the funds will support general building maintenance. If we raise less, we’ll use available funds to make essential repairs first.” That’s completely transparent, and donors know exactly what might happen to their money.

If you need personalised charity support with marketing and fundraising, book your call today.

Working with Volunteers, Vulnerable People and Partners

Most charities don’t fundraise in isolation; they work with volunteers, engage with vulnerable people, and partner with external agencies. The Code sets clear standards for managing all these relationships responsibly.

1. Supporting Volunteers Effectively

Volunteers bring incredible passion and genuine community connection to fundraising, but they also need proper support and boundaries. The Code distinguishes between two fundamentally different types of volunteers.

In-aid-of volunteers are people fundraising independently for your charity, like someone running a marathon and asking friends and family for sponsorship. On-behalf-of volunteers are people fundraising as official representatives of your charity, like volunteer collectors at events or in shops.

For on-behalf-of volunteers, you must provide appropriate training covering legal and safe fundraising practices, explain clearly how to handle and process donations, clarify what should and shouldn’t appear in fundraising materials, set clear behaviour expectations, offer ongoing support and guidance when needed, conduct appropriate checks to ensure they’re suitable representatives, and cover reasonable expenses but never pay them for their time.

For in-aid-of volunteers who you know about beforehand, make sure they understand they should use “in aid of” language clearly, they’re personally responsible for organising their own fundraising safely, you won’t accept liability for their independent activities, and where to find guidance on legal and safe fundraising practices.

Here’s a practical example. Your charity has volunteer collectors at a local festival, so these are clearly on-behalf-of volunteers. You need to check their criminal records if appropriate for the role, train them thoroughly on acceptable approaches, provide sealed collection boxes and proper ID badges, explain complaint procedures clearly, and have insurance that covers them whilst working.

Compare that to someone who emails saying “I’m running a bake sale for your charity next month.” They’re an in-aid-of volunteer, so you respond with thanks and genuine encouragement, links to guidance on safe food handling and obtaining local permissions, clear instructions for transferring money to your charity, and a polite reminder that they should use “in aid of” language. You don’t need the same level of formal oversight for independent fundraising.

2. Safeguarding Vulnerable People

This is absolutely non-negotiable in modern fundraising practice. The Code requires clear safeguarding procedures for children under 18, people who lack capacity to make informed decisions, and people in vulnerable circumstances.

“Vulnerable circumstances” means someone might be temporarily or permanently unable to make fully informed decisions due to:

  • Mental health issues
  • Learning disabilities
  • Dementia or cognitive decline
  • Recent bereavement
  • Financial crisis
  • Addiction
  • Domestic abuse
  • Social isolation

You’re not expected to diagnose vulnerability medically, but fundraisers must be genuinely alert to warning signs and respond appropriately. You must:

  • Not accept donations if you know someone can’t make an informed decision
  • Return donations if you discover the donor lacked capacity at the time
  • Not ask under-18s for regular donations
  • Have clear procedures for fundraisers to report concerns
  • Protect fundraisers themselves from harm whilst working

Here’s a real scenario. A major donor calls to increase their monthly direct debit from £20 to £100, but your fundraiser notices the donor sounds distressed, mentions recent bereavement, seems to be making the decision impulsively, and appears unclear about her financial situation. The right response is to thank her warmly for thinking of the charity, suggest she take some time to consider such a significant increase, and offer to call back in a few weeks when she’s had time to reflect.

Yes, you potentially lose £1,200 in annual income, but you protect someone vulnerable and maintain essential trust. That’s what ethical fundraising requires, and it’s the right thing to do every single time.

When working with children specifically:

  • Activities must be age-appropriate
  • Under-16s shouldn’t have overall responsibility for handling money
  • You must get permission before contacting children at schools
  • Get appropriate permission before using photographs of children
  • Follow strict age restrictions for collections.

3. Managing Third-Party Fundraisers

Many charities outsource fundraising to specialist agencies for telephone campaigns, face-to-face recruitment, event management, or commercial partnerships. The Code is absolutely clear; you remain fully accountable for their actions.

Before hiring any third-party fundraiser:

  • Conduct thorough due diligence
  • Check their track record thoroughly
  • Review their complaint history
  • Verify they genuinely understand Code requirements
  • Confirm they have appropriate insurance coverage

Your written agreement must include:

  • Detailed description of activities they’ll carry out
  • Clear timeline and deadlines
  • Explanation of how payment will be calculated if applicable
  • Copyright arrangements for fundraising materials
  • Confidentiality requirements
  • Behaviour expectations and Code compliance
  • Complaint procedures
  • Monitoring measures
  • Clear exit terms if you need to end the agreement quickly

You must monitor actively by:

  • Reviewing complaints regularly
  • Listening to call recordings if relevant
  • Observing street fundraisers in person
  • Checking data protection compliance systematically
  • Verifying solicitation statements are correct

Here’s a scenario to think about. A national charity hired a call centre to recruit regular givers, but three months in, complaints spiked dramatically. The charity investigated and discovered the agency was:

  • Calling people registered on the Telephone Preference Service
  • Not accepting “no” after first refusal
  • Making exaggerated claims about impact
  • Calling people after 9 pm

The charity:

  • Suspended the campaign immediately
  • Contacted all donors recruited to apologise personally
  • Offered them easy cancellation options with no pressure
  • Terminated the agency contract
  • Reported the issues to the Fundraising Regulator.

This hurt short-term income significantly, but it protected the charity’s reputation and demonstrated genuine accountability to donors and the regulator.

Professional fundraisers and commercial participators have specific legal definitions under the Charities Act 1992. Professional fundraisers are people paid to solicit donations on your behalf, whilst commercial participators are businesses that promote goods or services on the basis that they’ll donate to your charity. Both must give “solicitation statements” explaining how much they’re paid and how much you’ll receive. The rules are highly specific and legally required, so if you work with either type, study the relevant sections of the Code extremely precisely.

Standards for Specific Fundraising Methods

Different fundraising methods have specific requirements beyond the universal standards. Let me break down the main ones in practical detail.

1. Public Fundraising (Streets, Doors and Events)

Public fundraising includes:

  • Street collections
  • Door-to-door collections
  • Collections on private sites (like outside shops or in shopping centres)

General behaviour standards require:

  • Being clear you’re fundraising from the very start of any interaction
  • Not misleading people about why you’re approaching them
  • Not claiming a conversation “isn’t about fundraising” when it obviously is
  • Treating locations with genuine respect
  • Not causing obstructions or nuisance to the public or businesses

The famous three-step rule for street fundraising states that if you approach someone, you can take up to three steps alongside them. If they haven’t stopped within those three steps, you must end your approach immediately and not follow them. Once you’ve successfully started a conversation, you can walk with them to your promotional stand.

You must position yourself at least three metres away from:

  • Shop entrances
  • Pedestrian crossings
  • Cash machines
  • Station entrances
  • Market stalls
  • Other street traders

Street collections can happen 9 am-7 pm Monday-Saturday and 10 am-7 pm Sundays and holidays, whilst door-to-door collections can happen 9 am-9 pm Monday-Saturday and 10 am-9 pm Sundays and holidays, unless your licence specifies different times.

Door-to-door specific rules state you must:

  • Not approach properties with “no cold-callers” signs
  • Respect no-cold-calling zones
  • Not approach in groups larger than two people
  • Only knock on front doors unless invited elsewhere
  • Not ask to enter properties, only entering if clearly invited
  • Never stop residents from closing their door

Most public collections need licences or permissions well in advance. Street collections need a licence from the local council or Metropolitan Police in London, door-to-door collections need a licence under the House to House Collections Act 1939 or an exemption order, and private sites need written permission from the property owner. Plan ahead because applications can take weeks to process.

Fundraisers need proper ID badges showing a recent photo, the fundraiser’s identity, charity name and contact details, signature or authorisation, and the professional fundraiser’s name and contact if applicable. Badges must be credit-card size or larger and worn where clearly visible.

2. Digital and Social Media Fundraising

Digital fundraising is now absolutely mainstream, but it comes with specific requirements. Your website and donation pages must:

  • Make contact details easy to find
  • Explain clearly how you process personal data
  • Show processing fees before requesting any payment details
  • Include charity registration number and company details
  • Make secondary purposes clear if fundraising for specific projects

Social media campaigns must:

  • Not make claims you can’t properly evidence
  • Use case studies responsibly with informed consent
  • Not share shocking content purely to grab attention
  • Include appropriate warnings for sensitive content whilst following advertising standards

Email and electronic marketing:

  • Can only email people who’ve explicitly given permission
  • Must include clear unsubscribe options in every single email
  • Must remind people how to update their preferences
  • Must respect opt-outs immediately
  • Must check regularly against preference services like TPS, MPS, and FPS

Text message donations must:

  • Use charity short codes in the 70000-70999 range
  • Make costs absolutely clear
  • Provide simple opt-out instructions
  • Follow Ofcom guidance thoroughly

If you use third-party platforms like JustGiving or GoFundMe:

  • Ensure they meet Code standards
  • Check their fees are completely transparent
  • Verify they have proper procedures for removing inappropriate campaigns
  • Understand how quickly they transfer funds to you

GDPR and data protection are crucial and genuinely complex. Key requirements include:

  • Having a clear privacy policy
  • Only collecting data you actually need
  • Keeping data secure
  • Not sharing or selling data without proper consent
  • Allowing people to access, correct, or delete their data
  • Keeping detailed records of your data processing decisions

The Information Commissioner’s Office provides detailed guidance on fundraising and data protection that’s essential reading.

3. Events and Challenge Activities

Event fundraising is extremely popular but carries significant risks around health and safety, insurance, participant expectations, and financial commitments.

Planning requirements include:

  • Conducting a thorough risk assessment
  • Arranging appropriate insurance coverage
  • Having clear health and safety plans
  • Obtaining necessary licences and permissions
  • Checking local guidance for the venue
  • Creating plans for all reasonably foreseeable situations

Before someone signs up, they must know:

  • Registration fees (if any)
  • Minimum fundraising targets
  • Age, fitness, or training requirements
  • Whether the funds they raise cover their costs
  • What happens if they can’t participate
  • Refund policies

Sponsorship forms must make clear:

  • Any conditions for receiving the sponsorship
  • What happens if conditions aren’t met
  • How sponsors will be updated if the event is cancelled

After the event:

  • Follow up on minimum sponsorship requirements
  • Help participants chase unpaid pledges
  • Process funds quickly
  • Thank everyone involved

4. Raffles, Lotteries and Prize Competitions in Fundraising

These are genuinely popular but regulated by gambling law. Most lotteries need a licence or must be exempt, prize competitions must include an element of skill, free draws don’t need licences, and different rules apply depending on size and type.

Code requirements state you must:

  • Have written authorisation from the charity
  • Publish organiser’s name
  • Make terms and conditions easily accessible
  • Conduct draws fairly and randomly
  • Record results properly
  • Contact winners within seven days
  • Make winners’ details public (unless they opted out)

What good practice looks like includes:

  • Clear rules about who can enter
  • Being transparent about odds of winning
  • Honesty about prize values
  • Simple process for claiming prizes
  • Proper records for audit purposes

The Gambling Commission provides detailed guidance on fundraising lotteries.

5. Payroll Giving

Payroll giving allows employees to donate directly from their salary before tax is deducted. Standards for agencies and professional fundraisers include:

  • Making clear that donors can cancel anytime
  • Not offering benefits in return for donations
  • Following donors’ wishes about which charities receive funds
  • Representing each charity fairly if working for multiple organisations
  • Being clear, donors can give to any charity of their choice

For workplace access:

  • Get employer permission before approaching employees
  • Agree on conditions for access in writing
  • Wear photo ID at all times whilst on site

6. Legacy Fundraising

This is particularly sensitive because people are thinking about death and family. General standards require:

  • Respecting testators’ freedom to provide for family
  • Making sure information for wills is clear and accurate
  • Never claiming to provide legal advice
  • Considering conflicts of interest extremely thoroughly

When making personal contact:

  • Be open about why you’re inviting someone to legacy events
  • Don’t pressure anyone whatsoever
  • Conduct meetings sensitively
  • Keep detailed records of meetings
  • Accept people’s right to decline or end meetings
  • Allow people to bring others to meetings

If you pay for someone’s will in exchange for including a legacy:

  • Don’t insist on receiving a legacy
  • Don’t require being named executor
  • Provide clear information about the service
  • Offer at least two will-writer options
  • Make clear the writer acts for the testator, not you
  • Recommend independent legal advice

To protect against undue influence:

  • Fundraisers must not draft wills
  • Fundraisers must declare any offers of personal legacies to management
  • Have clear procedures for dealing with personal legacy offers
  • Follow disciplinary procedures if fundraisers take advantage of their position

The Four Principles of Fundraising in Action

Let me show you how Legal, Open, Honest, and Respectful play out in actual fundraising situations.

1. Legal Means Proactive Compliance

Legal doesn’t just mean “not breaking the law,” it means proactively ensuring compliance. Before running any raffle or lottery, charities need to check whether they need a licence, what age restrictions apply, prize value regulations, and record-keeping requirements. Proper compliance means checking the rules beforehand and documenting decisions, not hoping everything will be fine.

2. Open Means Genuine Transparency

Open means explaining what you’re doing and being willing to discuss your processes honestly. When charities work with telemarketing agencies or other third-party fundraisers, transparency means publishing which agencies they work with, how they monitor them, how people can opt out, where to complain if something goes wrong, and what the activities cost. When donors ask questions, answering fully without defensiveness or hiding behind “commercial confidentiality” demonstrates the Open principle in practice.

3. Honest Means Complete Integrity

Honest means not misleading people, even by omission. When fundraising appeals exceed their targets, charities face a choice. The honest approach is updating donors that the target was exceeded, explaining how additional funds will be used, and offering refunds to anyone who wants them. Quietly redirecting surplus funds without telling donors violates the Honest principle, even if it’s technically within your powers.

4. Respectful Means Valuing People

Respectful means valuing people’s time, privacy, and dignity in every interaction. When someone indicates they want to end a conversation, accepting that immediately shows respect. Asking “Can I just finish explaining?” or saying “It’ll only take one more minute” or making people feel guilty violates the Respectful principle. Genuine respect means accepting “no” without pressure or manipulation.

5. How the Four Fundraising Principles Connect

These four principles work together seamlessly. Being Legal without being Open creates suspicion, being Honest without being Respectful can hurt people, and being Respectful without being Legal exposes your charity to serious risk. They’re not separate boxes to tick mechanically; they’re interconnected values that should guide every single fundraising decision you make. If you’re not sure whether something meets the Code, ask yourself if it’s Legal, Open, Honest, and Respectful. That simple test catches most problems before they happen.

Why Compliance Protects Your Charity

Let me be direct about the real risks of non-compliance. Reputational damage means one bad news story can undo years of good work. Your reputation is your most valuable asset, and the Code helps protect it systematically.

Financial consequences go beyond lost donations to include:

  • Legal costs if serious breaches occur
  • Cost of investigation and remediation
  • Potential fines or penalties
  • Loss of grant funding
  • Increased insurance premiums

The Fundraising Regulator can:

  • Publish findings from investigations
  • Require removal of the Fundraising Badge
  • Refer serious cases to statutory regulators
  • Name charities publicly for non-compliance

The Charity Commission has additional powers to:

  • Issue official warnings
  • Open statutory inquiries
  • Remove trustees
  • Freeze bank accounts in serious cases

1. The Positive Case for Compliance in Fundraising

Contrast those risks with how charities can turn compliance into a genuine strength. When charities respond constructively to complaints, they demonstrate their commitment to ethical practice. This means investigating thoroughly, identifying where improvements are needed, revising procedures, reaching out to complainants to explain changes, and publishing lessons learned for transparency.

The Fundraising Regulator specifically looks for constructive engagement when issues arise. Charities that respond positively to concerns, rather than defensively, often find that trust increases rather than decreases. Strong compliance becomes part of their reputation, something they can highlight in funding applications, volunteer recruitment, and annual reports. Compliance doesn’t cost you opportunities; it creates them.

2. How Compliance Strengthens Your Charity

When charities face serious compliance issues, the path forward involves systematic improvement. Common problems include inadequate monitoring of third-party partners, weak contracts with unclear standards, insufficient training for fundraisers, absent complaint handling processes, and poor data protection practices.

Addressing these issues requires a complete approach. This typically means reviewing all third-party arrangements and strengthening oversight, bringing critical functions in-house when necessary with proper training, creating clear written policies for all fundraising methods, establishing regular trustee reporting on complaints and compliance, appointing someone responsible for compliance oversight, and registering with the Fundraising Regulator to demonstrate commitment.

The benefits of taking compliance seriously extend beyond avoiding problems. Complaint rates fall when proper systems are in place. Donor retention improves when people trust your processes. Income grows sustainably when reputation strengthens. Staff feel more confident in their work when they know they’re operating ethically. Recognition from funders and the sector follows a genuine commitment to standards.

Investment in compliance pays for itself through reduced complaints, better donor relationships, and sustainable income growth. More importantly, it protects what matters most: your integrity, your relationships with supporters, and your future ability to deliver your mission. That’s what compliance truly protects, not just your legal position but the trust that makes your work possible.

Making the Fundraising Code Work in Practice

Right, theory is great, but how do you actually implement this in practice? Let me give you a practical roadmap that works for charities of different sizes.

1. Train Your Team Properly

Everyone involved in fundraising needs Code training, and I genuinely mean everyone, including:

  • Trustees
  • CEO and senior leadership
  • Fundraising staff
  • Communications team
  • Finance staff who process donations
  • Volunteers
  • Third-party partners

Training should cover:

  • Overview of the four principles
  • Specific standards for their role
  • How to recognise vulnerability
  • When to refuse donations
  • Complaint handling procedures
  • Data protection basics
  • What to do when they’re unsure about something

For trustees, deliver an annual workshop lasting 2-3 hours covering governance responsibilities. For staff, provide half-day induction for new starters, annual refresher training, and monthly team discussions of real scenarios. For volunteers, offer a briefing session before they start, written guidance they can keep, and accessible support whilst fundraising. For partners, include written materials in contracts, hold annual compliance review meetings, and conduct spot-check observations.

Don’t just lecture people endlessly. Use scenarios and role-play exercises like “You’re doing a street collection and someone wants to donate £500 cash. What do you do?” or “A donor calls upset that you contacted them after they opted out. How do you respond?” or “You notice a colleague being too pushy with a potential donor. What’s your next step?” These discussions build genuine confidence and professional judgement.

2. Write Effective Policies That Get Used

You need written policies for fundraising approach covering methods you use and don’t use, behaviour standards, how you work with partners, and safeguarding procedures. Donor relations policy should cover how you communicate, how often you contact people, preference management, and opt-out procedures.

Accepting and refusing donations policy needs a due diligence process, circumstances when you’d refuse donations, how decisions are made and documented, and a refund policy. Complaints policy should explain how people can complain, who handles complaints, response timeframes, how you learn from complaints, and how to escalate to the Fundraising Regulator.

Data protection policy must cover what data you collect and why, how you keep it secure, who you share it with, how long you keep it, and people’s rights over their data.

These policies don’t need to be complicated documents. I’ve seen excellent policies that fit on three to four pages, and I’ve seen terrible policies that run up to 40 pages that nobody ever reads. Clear and practical beats comprehensive and theoretical every single time.

3. Conduct Regular Reviews and Audits

Compliance isn’t set-and-forget; it requires ongoing attention. Monthly, you should:

  • Review all fundraising complaints
  • Check key metrics like complaint rate, opt-out rate, and processing errors
  • Spot-check donation processing
  • Review any incidents or near-misses

Quarterly, you need to:

  • Report to trustees on compliance and complaints
  • Review the training success
  • Check all licences and permissions are current
  • Monitor third-party partners systematically

Annually, you must:

  • Conduct a full compliance audit against the Code
  • Review the charity policies
  • Update risk assessments
  • Refresh training materials
  • Check insurance coverage remains adequate

A simple audit means going through each section of the Code and, for each requirement, asking:

  • Does this apply to us?
  • If yes, how do we meet it?
  • What evidence can we show?
  • Are there any gaps?
  • What’s our action plan?

Create a simple spreadsheet tracking this, update it quarterly, and share it with trustees regularly.

4. Protect Donor Data with Secure Systems

This deserves special attention because it’s genuinely complex and high-risk. Basic requirements include:

  • Privacy policy on your website
  • Consent records for marketing
  • Secure database with appropriate access controls
  • Regular backups
  • Clear retention periods
  • Process for handling data subject access requests

Practical steps include:

  • Auditing what data you hold and why
  • Deleting anything you don’t actually need
  • Checking your database against preference services monthly
  • Using a reputable CRM system, not Excel spreadsheets
  • Training staff on data protection, not just fundraisers
  • Having a breach response plan ready

Common mistakes I see constantly include:

  • Buying email lists (don’t do this)
  • Using pre-ticked consent boxes (not valid)
  • Keeping data forever without a retention policy
  • Sharing data with partners without proper agreements
  • Having no process for unsubscribe requests

The ICO has excellent practical guidance specifically for charities that you should use.

5. Report Transparently

Show your stakeholders you take compliance seriously. In your annual report:

  • State your commitment to the Code
  • Report key metrics (complaint numbers, resolution rates)
  • Explain your fundraising approach
  • Show the Fundraising Badge if registered

On your website:

  • Clear complaints procedure
  • Link to privacy policy
  • Information about fundraising methods
  • How to opt out or update preferences

To donors:

  • Honest communications about impact
  • Clear information about costs
  • Updates when things change
  • Thanks and recognition

Transparency builds trust, and trust builds sustainable income over the long term.

6. Implement Quick Wins for Your Charity

I know some of you are thinking, “This sounds expensive and complicated,” but it doesn’t have to be at all. Here are quick wins that cost nothing but time.

This week, check your donation page shows fees clearly, add unsubscribe links to email templates, create a simple complaints procedure, and review your privacy policy or create one if it doesn’t exist.

This month, brief all volunteers on basic Code requirements, audit what licences and permissions you need, check you’re not on anyone’s “do not contact” list, and create your first policy (v.1) on accepting & refusing donations.

This quarter, review your website against Code requirements, conduct due diligence on any partners, put written agreements in place, and train trustees on their fundraising responsibilities.

These steps don’t require consultants or big budgets, just commitment and organisation. Start small, build momentum, and compliance becomes easier once it’s embedded in your culture.

My Final Thoughts

I’ve spent over 14 years working in the charity sector, and I’ve seen incredible generosity, witnessed transformative impact, and watched communities come together for causes they believe in deeply. But I’ve also seen damage caused by poor fundraising practices, including donors being misled about how their money would be used, and personal data being mishandled.

Every one of those incidents erodes public trust, and public trust is the foundation everything else is built on. The Code of Fundraising Practice 2025 isn’t bureaucracy; it’s a framework for maintaining and rebuilding that essential trust. It’s a commitment that says “we’ll do right by our donors, even when no one’s watching,” and it’s recognition that how you raise money matters as much as how much you raise.

Following the Code actually makes you better at fundraising, not worse. When donors trust you, they give more generously. When supporters feel respected, they stick with you longer. When your reputation is strong, you attract better partners, more volunteers, and bigger opportunities. Ethical fundraising is sustainable fundraising.

What kind of organisation do you want to be? What legacy do you want to leave? How do you want donors to feel after interacting with you? The Code helps you answer those questions consistently, across every interaction, every single day.

Start with an honest assessment of where you are now. Where are you strong? Where are the gaps? What’s the biggest risk you’re carrying? Don’t try to fix everything at once; just pick three priorities, create an action plan, get trustee support, allocate some budget, and start making changes.

If you need help with marketing and fundraising strategies or charity governance, book your call today to get the support you need. You don’t have to do this alone.

Frequently Asked Questions

View FAQs

Do I really need to follow the Code if I’m a small charity?

Yes, absolutely. The Code applies to all charitable fundraising regardless of size, but remember it’s principles-based. “Appropriate” measures for a charity with three volunteers look completely different from measures for a charity with 50 staff. You need to follow the Code, but you can do so proportionately to your size and resources.

What happens if someone complains about my fundraising?

First, try to resolve it directly with a clear complaints procedure, respond quickly and fairly, and learn from the complaint. If the complainant isn’t satisfied, they can contact the Fundraising Regulator, who will investigate if necessary. If they find you broke the Code, they’ll publish their findings, which can damage your reputation, so take complaints seriously from the very start.

Can I still use professional fundraising agencies?

Absolutely, many charities work successfully with agencies. But you remain responsible for their actions, so you must do proper due diligence before hiring them, have strong written contracts, monitor their work actively, and ensure they follow the Code. Don’t outsource and forget, stay involved and accountable.

How do I know if someone is vulnerable?

You’re not expected to diagnose vulnerability medically, but be alert to signs like confusion or difficulty understanding, making impulsive decisions, mentioning recent bereavement or crisis, already supporting many charities beyond their means, or difficulty communicating or comprehending. When in doubt, slow down and give people time and space to make informed decisions.

Do volunteers need DBS checks?

It depends entirely on their role. For on-behalf-of volunteers who’ll have contact with children or vulnerable adults, yes, definitely. For casual volunteers collecting at a one-off event, basic checks might be appropriate. For in-aid-of volunteers fundraising independently, generally no. The law specifies when you can request different levels of DBS checks, so only request checks you’re legally entitled to.

What’s the difference between Gift Aid and processing fees?

Gift Aid is tax relief claimed from HMRC on eligible donations that increases the value of the donation by 25%. Processing fees are charges from payment processors, banks, or fundraising platforms that reduce the amount you receive. Both should be explained clearly to donors, but they’re completely different things.

Can I contact people who haven’t given me permission?

It depends on the method. For postal marketing, you can contact people who haven’t explicitly opted in unless they’ve registered with the Mailing Preference Service. For email and text marketing, you need consent first, with limited exceptions for existing supporters. For phone calls to individuals, check the Telephone Preference Service. For phone calls to businesses, different rules apply. Data protection law is genuinely complex here, so get proper advice for your specific situation.

How often should I contact donors?

There’s no set rule in the Code. You must be able to justify your contact frequency by balancing keeping supporters engaged with not overwhelming them. Consider what supporters have consented to, their relationship with you, the urgency of your messages, and feedback and complaint rates. Many charities contact regular givers 1-2 times per month, major donors more frequently, and lapsed supporters less often. Always make it easy for people to adjust their preferences.

What if I can’t afford compliance?

Basic compliance costs very little in practice. Reading the Code is free, writing simple policies takes time, not money, and training your team can use free resources. Where you might need investment is:
Database systems that handle preferences properly
DBS checks for volunteers
Professional advice on complex situations
Insurance for events
But remember, non-compliance is much more expensive through lost donations, reputational damage, and regulatory action. Start with free resources and build from there.

Where can I get more help?

The Fundraising Regulator provides free guidance and Code support guides. The Information Commissioner’s Office offers data protection guidance for charities. Charity Commission provides fundraising and governance guidance. Chartered Institute of Fundraising delivers training, resources, and best practice.
Evolve Catalyst offers practical compliance support and mentorship for small charities.
Start with these resources because most questions have already been answered.

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Ghamdan Al-Areeky

Ghamdan Al-Areeky

Founder & Charity Mentor

Founder of Evolve Catalyst and a charity mentor helping small and medium-sized charities build the systems, strategy, and structure they need to grow sustainably. With 15+ years of experience across operations, governance, crisis recovery, and leadership, I work closely with founders, trustees, and boards to strengthen organisations and create long-term resilience. My approach is practical, collaborative, and focused on solutions that work in the real world, not just on paper. You don’t have time to waste figuring it out alone; I bring the experience and frameworks to help your charity thrive.

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