The Fundraising Preference Service should not apply to charities with annual incomes of less than £1m, according to proposals from the working group set up to consider the scheme.
The group, which is chaired by George Kidd, who also chairs the Direct Marketing Commission, has published a discussion paper on proposals for the FPS, which would enable people to opt out of receiving all fundraising communications by mail, email and telephone.
It says the service must provide a "reset button" that people can use to block all communications from charities. But it adds that, for practical reasons, fundraising organisations with incomes of below £1m a year should not be required to check their fundraising campaigns against the FPS.
The paper says the FPS should also give users the option of listing organisations from which they wish to continue receiving fundraising communications.
It says the FPS should not prevent charities from contacting people when the purpose of the communication is not a solicitation.
This would include such communications as a message to thank someone for a donation, letters containing information about the organisation’s activities and how to get involved, or contact for the purpose of managing a direct debit, providing none of these activities were used as a means to ask for funds or higher contributions.
The proposals say the FPS should not apply to households, which means unaddressed mail would not be covered.
The paper says the working group would therefore welcome feedback on whether the exclusion of unaddressed mail would cause "unwanted consequences, such as a dramatic rise in the use of this method of communication".
The working group also calls for feedback on whether registration with the FPS should relate to a single principal address, one email address and a landline and/or mobile number.
The paper says FPS registration should not be time-limited and that the service should enable people to amend their entries to ensure their contact details are up to date.
Peter Lewis, chief executive of the Institute of Fundraising, said in a statement that the umbrella body continued to have concerns about a generalised reset button.
"The IoF is absolutely committed to ensuring that members of the public are not overwhelmed or feel under pressure to donate, and we have already made significant changes to the Code of Fundraising Practice to ensure charities respond better to donor preferences," he said.
"Ensuring donor choice should be absolutely fundamental to the new regulatory system as a whole. It needs to be carefully thought through, especially as to how the FPS will work alongside the new EU regulation on data protection, which will require consent freely given, specific, informed and unambiguous, and any new guidance from the Information Commissioner’s Office in relation to consent.
"In this context we continue to have concerns over a generalised reset button and believe much more detailed thinking and analysis is required."
The consultation runs until 31 March.