In June, the regulator began asking to see Criminal Records Bureau disclosures for trustees of all new charities dealing with vulnerable groups. This move came after an expose by the Daily Mirror, which set up a false charity in the name of a convicted paedophile.
The commission had registered Give Kids a Break, despite the fact that the named founder, John Harrison, had a conviction for possessing the largest recorded collection of child pornography.
Although the application said Harrison, who will be on the sex offenders' register for life, would work directly with children, his criminal past was not checked.
At the time, Andrew Hind, chief executive of the commission, said: "We accept there needs to be a foolproof system to protect children and vulnerable beneficiaries."
A spokesman for the commission said the aim of the 12-week consultation was to ensure the system was effective and avoided duplication.
Clare Smith, HR director at Leonard Cheshire, said: "I don't think it's necessary for the commission to see the CRB checks.
"The majority of charities are well versed enough to make a decision about whether an individual is suitable.
"The commission should carry out spot inspections to ensure everyone is carrying out CRB checks for trustees."
The consultation closes on 11 May. See www.charitycommission.gov.uk.