Ask a small charity when it last received a fundraising complaint, and the usual answer is never.
The Fundraising Regulator defines a complaint as an expression of dissatisfaction, however made, about something done or not done. However made; so the remark at the summer fair, the Facebook comment about too many emails, the supporter who mentions being surprised to get a third letter. None of those arrives labelled as a complaint, and all of them are one.
The guidance adds a rule worth adopting outright: if you’re unsure whether something is a concern or a complaint, treat it as a complaint.
If you have no procedure and no record of what people have raised, that’s a governance gap rather than a fundraising one.
The procedure you’re required to have
The Code is direct. You must have a clear and publicly available fundraising complaints procedure that your fundraisers can explain to donors and potential donors.
Three words there do the work. Clear means simple enough that someone upset can follow it. Publicly available means on your website, findable, not buried. And fundraisers can explain it means the volunteer on the stall knows what to say when someone is unhappy.
There’s a second requirement about anyone fundraising alongside you. If a fundraising partner doesn’t have a suitable published procedure of their own, they must agree to follow yours. That belongs in the agreement before they start, not in the conversation after something goes wrong.
What the procedure needs to say
The Regulator expects it to set out the scope of complaints you can consider, and what complainants can and cannot expect from you. Being honest about the limits is part of the point – a procedure that implies you’ll investigate anything creates a second complaint when you don’t.
It should include timescales for each stage, and the remedies available. An apology is a remedy, and often the one the person wanted.
And it must signpost onwards. If you can’t resolve the complaint, the procedure should direct people to the Fundraising Regulator, or to the Scottish Fundraising Adjudication Panel where that applies.
Internally, it needs one more thing the public version doesn’t: who a complaint gets passed to. Staff and volunteers should know where it goes, so nothing sits in an inbox for three weeks because nobody was sure whose job it was.
When one arrives
Acknowledge it. Then explain what will happen and when a decision will be made – the Regulator asks for both at the acknowledgement stage, and it’s the single easiest thing to get right.
Set time limits you can actually meet. If you then can’t meet them, tell the person before the deadline passes and explain why. Silence turns a resolvable complaint into an escalated one more reliably than a wrong answer does.
Listen for what they actually want. The Regulator puts it plainly: understand the complaint and the outcome they’re seeking. Sometimes it’s money back, but far more often it’s an apology, an explanation, or an assurance it won’t happen again – all of which are cheaper and faster than what you might have assumed they wanted.
No procedure, and no idea what’s been raised over the years?
Most small charities discover they’ve handled complaints informally for a decade with nothing written down. A free Charity Consultation will help you build something proportionate rather than borrowed from a charity ten times your size.
The independence problem
Here’s where small charities get stuck. The Regulator says complaints should, where possible, be investigated by someone independent of the events complained about.
In a charity with two staff and five trustees, the person complained about may be the only person who knows anything about it, and the person who’d normally investigate may be their line manager, their friend, or both.
The guidance answers this directly: where independence isn’t possible internally, consider asking a third party outside the organisation to investigate.
For a small charity, that usually means a trustee with no involvement in fundraising, or – for anything serious – someone outside the charity entirely. What it can’t mean is the person complained about assessing whether the complaint has merit.
Deciding this in advance is much easier than deciding it while someone waits for an answer. Your procedure should name who investigates when the usual person can’t.
The person complained about has rights too
This gets forgotten, particularly with volunteers.
Where possible, tell someone a complaint has been made about them or about actions they were responsible for. Give them a chance to respond to what’s been alleged. The Regulator is explicit that you owe a duty of care to the person complained about as well as to the complainant.
A volunteer who learns from a third party that they were investigated, and who was never asked for their side, is a volunteer you have lost – and quite reasonably.
Investigate properly. Look at the evidence, speak to the complainant, speak to anyone complained about, and speak to third parties where relevant.
Answering
Give clear, evidence-based reasons, and make the decision proportionate, appropriate and fair.
Respond to all the substantive points the person raised, and say why each is justified or not. A reply that addresses the easy point and skips the hard one is how complaints reach the Regulator.
Be respectful and acknowledge their experience, whether the complaint is upheld or not. Someone can be wrong about what happened and right about how it felt.
Where something did go wrong, say so, put it right proportionately, and apologise. Take responsibility for the actions of your staff and of anyone acting on your behalf, including agencies and volunteers.
Then close the loop most charities leave open: tell them what you’ve learned and what you’ve changed. That single paragraph converts more complainants back into supporters than anything else in the process.
Recording, reviewing, reporting
Keep a record of every complaint, what the investigation found, and why you decided as you did.
Review them regularly for patterns. One complaint about a mailing is a complaint. Four about the same mailing is a mailing problem – and it’s usually a supporter data problem underneath, which is the argument in joining up supporter data.
And report to the board. The Regulator expects regular reporting on the number and nature of complaints, their outcomes, and whether anything changed as a result. That’s not a large charity requirement. A line on the agenda and a note in the minutes covers it for most small charities, and it’s part of what makes fundraising oversight visible rather than assumed – the wider trustee duties are in the Code of Fundraising Practice.
One reporting duty to check against your own position: charities in England and Wales required by law to have their accounts audited must include information about fundraising complaints in their annual report, under the Charities (Protection and Social Investment) Act 2016. Most small charities sit below that threshold, though the audit threshold is moving for financial years ending on or after 30 September 2026.
If it reaches the Regulator
The Fundraising Regulator investigates complaints that organisations can’t resolve themselves, by asking whether the Code was followed. So the first opportunity is yours, and most complaints end there when handled properly.
If it does escalate, what helps you is the record: what was raised, what you did, what you found, what you told them. A charity that investigated fairly and can show it is in a very different position from one that has nothing written down.
Charities can also self-report to the Regulator where something has gone seriously wrong. And some complaints will be serious incidents in their own right, with their own reporting route to the Charity Commission.
Complaints are unpleasant, and they are useful. The ones that damage a charity are almost never the ones that were handled badly at the start – they’re the ones nobody recorded, nobody reviewed, and nobody told the board about.
If you need the procedure written and the process agreed rather than another article about it, a one-off governance project will get it done.
