The CFDG used its accounts to provide an exemplar of a public benefit statement, which will become a requirement for all charity reports next year.
Intelligent Giving said the report was "one of the best we've seen", but Adam Rothwell, its director, felt public benefit should be reported differently.
"We're extremely pleased the CFDG has chosen to include a public benefit statement," he said. "However, there's a problem at the heart of it.
"It's demonstrated public benefit in a technical way, but it hasn't demonstrated the impact it's made - it hasn't shown what moves it's made towards its vision.
"It shows how the CFDG hit its targets, but not how it's made the world a better place."
But Keith Hickey, chief executive of the CFDG, said: "Our vision is a transparent and efficiently managed charity sector that engenders public confidence.
"We feel that we do demonstrate we are advancing our vision in the annual report. Advancing our vision is the product of individuals changing their behaviours in charities."