Proposed changes to charity law in Scotland are just "tinkering around the edges" and fail to address key areas of concern, according to Anna Fowlie, chief executive of the Scottish Council for Voluntary Organisations.
Fowlie has written to Aileen Campbell, Cabinet Secretary for Communities and Local Government, asking her to "carry out a more comprehensive review", and describing the current one as a "missed opportunity".
The Scottish government opened a consultation in January on its proposals to amend charity law, which it said would increase trust and improve transparency in the voluntary sector.
The proposals include creating a register of trustees and removing from the register any charities that don’t "have and retain a connection in Scotland".
But Fowlie's letter says the proposals do not go far enough to deliver a comprehensive review of Scottish charity law.
"There is a real risk that the current proposed changes are simply tinkering around the edges, when the environment that charities now operate in has changed significantly since the Charities and Trustee Investment (Scotland) Act was passed in 2005," she wrote.
"Given that legislative time is scarce, we think this is a missed opportunity and would ask you to broaden out the scope of the review."
The SCVO submission to the consultation called on the Office of the Scottish Charity Regulator to be made independent of government and legally required to report to the Scottish parliament rather than to ministers.
It also urged the government to work with charities and the OSCR to redefine public benefit, which Fowlie's letter says was being "misused".
John Downie, director of public affairs at the SCVO, told Third Sector: "SCVO has long believed that arms-length organisations of councils and private schools are not genuine third sector organisations.
"They are examples of muddying the water around what it means to be a modern charity in Scotland today."
The consultation ended on 1 April, but Fowlie’s letter urges Campbell to "take the time needed to create a stronger foundation for the charitable sector in Scotland" and offers to meet to discuss her concerns.
Third Sector asked the Scottish government to respond to Fowlie's letter but did not receive a reply before publication of this story.