Charity Commission publishes updated fundraising guidance

The new version of CC20 attracts mixed responses from sector bodies, with the Charity Finance Group expressing concerns that it focuses too much on costs


The Charity Commission’s new CC20 guidance for fundraising has been published today, attracting mixed responses from sector bodies.

The commission said that Charity fundraising: a guide to trustee duties (CC20), which calls for trustees to ensure that fundraising reflects their charity’s values, was part of its response to some of the high-profile problems identified with fundraising practices over the past year. It sets out six key principles aimed at helping trustees comply with their legal duties on fundraising.

The six principles include supervising fundraising, not simply delegating; protecting the charity’s reputation and having regard for its values when making decisions about fundraising; and being transparent, including about any commercial relationships. Advice is also included on effective planning, legal compliance and how to follow best practice.

The Institute of Fundraising and the National Council for Voluntary Organisations both said they were pleased with the guidance but the Charity Finance Group said it was worried that it focused too much on the costs of fundraising and overheads.

The new guidance states: "Very high fundraising costs can seriously damage a charity’s reputation" on page 12 and this message is echoed in various places in the document.

Anjelica Finnegan, senior policy and public affairs officer at the CFG, told Third Sector that while the CFG broadly welcomed the new guidance, it was concerned that the focus on fundraising costs rather than the outcomes of fundraising – such as improved services for beneficiaries – could lead to trustees overlooking the contribution fundraising made to their organisations.

"It doesn’t consider the fact that you might have high-fundraising costs but that proportionally you get a lot back and it’s valuable for your organisation," she said.

Peter Lewis, chief executive of the Institute of Fundraising, said he was happy with the guidance and that the commission appeared to have taken on board the IoF’s feedback to its consultation.

The IoF had said previously that the tone of the commission’s draft guidance was much stronger than the previous guidance, which could result in trustees becoming too risk averse. It also criticised the framing and language the commission had used.

But today he said he thought these issues had been resolved and that he was pleased the commission had made it clear where the responsibility lay for fundraising among employees and trustees.

He said it was positive that the new guidance stressed that trustees could delegate the responsibility for fundraising to employees but also said that they needed to maintain oversight over such activities. "We were worried in the draft that there was confusion about the difference between governance and strategic oversight, but that is much clearer now," he said.

Sir Stuart Etherington, chief executive of the NCVO and who carried out last summer’s review of fundraising self-regulation, was also positive about the guidance, calling it "practical and constructive".  

He said: "The principles set out in the guidance ensure trustees understand what is expected of them and, in particular, how general trustee duties apply to fundraising. 

"They will enable trustees to effectively oversee and, if necessary, challenge their charity’s fundraising practices."

He added that the focus on reputation throughout the guidance was prudent at a time when charities needed to consistently demonstrate that they were working to the highest standards.

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