In an interview with Third Sector Grade, who steps down as chair of the Fundraising Regulator in December, said there would have to be a conversation about the future of the non-statutory organisation if the government decided it no longer wished to fund the commission.
The Fundraising Regulator is funded through a voluntary levy of between £150 and £15,000 paid by charities that spend more than £100,000 a year on fundraising.
Cuts to the commission’s Treasury funding mean its budget has fallen by £8m since 2010 and will be frozen at £20.3m a year until 2020. Various models have been put forward to make up the shortfall by charging charities – for example, by requiring charities to pay a fee when submitting their annual accounts.
The commission, a statutory regulator, has been expected to launch a consultation on charging for the past two years. But there has been no suggestion that the government might remove all funding for the commission.
Grade told Third Sector he was not confident about the future of non-statutory regulation for a variety of reasons.
"If the government decides it doesn’t want to go on funding the Charity Commission and that the sector itself should fund it through a levy, then absolutely there’ll have to be a conversation about how that would work for the Fundraising Regulator," he said.
"If they go to a levy, the government and the sector would have to work out whether they get two levies or we get folded into the Charity Commission, and by virtue of that become statutory."
But he said the survival of the regulator was also down to the sector and whether it continued to support the regulator "emotionally and financially", including by paying the voluntary levy to fund it, which he acknowledges has "by and large" happened.
Grade said that the regulator could be at risk if "we were to get it wrong in a very big and controversial way".
A Charity Commission spokeswoman said it looked forward to reading Grade’s suggestions.
"We will soon be announcing our new strategy, which will set out to the sector and others what our mission and priorities will be," she said.
"It is right that we do this, before we go on to explore the options for ensuring we are resourced to deliver on that strategy. Ultimately, and regardless of the structures involved, the core purpose of regulating charitable activity and fundraising is that the public feels able to continue to support charities with confidence and that charity thrives and can maximise its impact in society."
To read the full interview, click here