One of the key recommendations in the Fundraising Standards Board investigation of Tag Campaigns, published in December, is that the street fundraising agency should commit itself to a 12-month programme of monitoring by the FRSB.
The investigation, prompted by a Sunday Telegraph investigation, found that Tag fundraisers had "deliberately misled, confused and obstructed" the public, breached the Institute of Fundraising code of practice and broken charity law by failing to make solicitation statements.
Tag accepted the findings and said it took immediate action to overhaul training and recruitment after the article was published. But it insists it is not prepared to accept a monitoring programme by the FRSB, of which it is not a member.
It says that it is open to discussing a monitoring programme with the Public Fundraising Regulatory Association, which it describes as the regulator of face-to-face fundraising.
A Tag spokesman says: "Tag voluntarily cooperated with an investigation by the FRSB - despite there being no complaint from a member of the public and even though, along with 90 per cent of the charity sector, it is not a member.
"As far as we are aware the FRSB has never before carried out monitoring of a face-to-face operation, or indeed any fundraising operation, and it does not appear to have the processes in place to enable it to do so in any meaningful way. It is therefore unclear why it would be better placed than the PFRA to oversee a monitoring programme.
"It has now been three months since a monitoring programme was first mooted by the FRSB, but in all that time there has been no detail about what the FRSB means by it, nor even a brief outline of a proposal. Tag remains open to discussing the idea, but while the suggestion remains so nebulous it is impossible to commit to it."
It is a moot point whether Tag is right to describe the PFRA as the regulator of face-to-face fundraising. A joint statement by the PFRA, the IoF and the FRSB last year said: "The FRSB should be the single public-facing regulatory body and point of contact for the public with regard to complaints relating to any kind of fundraising."
Alistair McLean, chief executive of the FRSB, says it is disappointing that Tag has not responded to its recommendation for a monitoring programme.
"We cannot compel it to be involved: it is not for us to force the company and it has chosen, thus far, not to engage with us,"
he said. The FRSB and the PFRA will meet to discuss the recommendations later this month, McLean says.
Ian MacQuillin, head of communications at the PFRA, which endorsed the findings of the FRSB's investigation, says the PFRA also plans to meet Tag separately later this month to discuss "how we can jointly implement the recommendations contained in the FRSB's adjudication".
Meanwhile, Tag faces fresh criticism after a second report in The Sunday Telegraph, published a week after the FRSB's adjudication, said that one of its fundraisers failed to make the solicitation statement. The campaign was for Shelter, which has suspended work with the agency.
According to Tag, the fundraiser involved no longer works for the company, but McLean says the incident raises questions about the effectiveness of the changes made to the company's procedures since June.
"The fresh allegations highlight the importance of our original recommendation that Tag should commit to a monitoring programme to assess the efficacy of its new systems," he says.