The OCS has stressed the need for BLF funding to complement that of other funders, including government, in a draft of new policy directions issued this week.
The directions were written after the government decided to transfer responsibility for the BLF from the Department for Culture, Media and Sport to the OCS.
Kevin Curley, chief executive of Navca, said: "Frankly, why would a major funder not be asked to complement and add value to the work of other funders, including government?
"It is something we would ask of funders – that they don’t plan funding alone and look at providing more impact through complementing others. I have no problem with it and I don’t think our members will."
The policy directions lists "additionality/complementarity" as the one of the principles the BLF should consider when distributing money.
Defining this, it says: "The development of programmes and funding of projects should complement and add value to the plans of action and activity of other funders and parties working towards the fund’s goals, including government funding."
This is different to the additionality principle described in the BLF’s latest annual report, which begins with a statement that "lottery funding is distinct from government funding and adds value". It goes on to say "where appropriate, it complements government and other programmes' policies and funding.
Jay Kennedy, head of policy at the Directory of Social Change, a training body that advocates on behalf of small charities, said there was already enough confusion about what is "additional" and that the new directions had missed a chance to provide clarity.
But Curley said the only thing in the directions he was unhappy about was the statement that money should be distributed to projects delivered "primarily" by the voluntary sector.
He said Navca would object to the word ‘primarily’ because it felt all funding should go to voluntary organisations.
A spokeswoman for the National Council for Voluntary Organisations declined to comment on the proposals, saying it would respond to the consultation before the 18 November deadline.