The fundraising think tank Rogare has recommended that small charities should not be exempt from the proposed Fundraising Preference Service.
Rogare, based at Plymouth University, was responding to a consultation run by the working group set up to consider the scheme, which will enable people to opt out of receiving all fundraising communications by mail, email and telephone.
The consultation document says charities with incomes of below £1m a year should not have to check fundraising communications against the FPS, but Rogare’s response says that, although it disagrees with the service in principle, if it is to happen it should apply to all charities.
"This is a tough call for us, because we want as many charities as possible to be able to conduct the level of sustainable fundraising they need to do in order to deliver services for beneficiaries," Rogare’s response says.
"However, the point of the FPS is that it allows people an option to reset to zero all the fundraising communications they receive.
"If they click the reset, but they still receive substantial levels of fundraising communications, we are concerned that this could severely damage trust in the Fundraising Regulator and the FPS and through that the practice of fundraising."
It says people who might otherwise have opted back into receiving charity communications might not do so because they are frustrated that the FPS has failed to prevent all fundraising asks.
"This might be an especially acute issue if small charities expand into direct marketing to fill the void left by larger charities," it says.
The Small Charities Coalition, which represents organisations with annual incomes of less than £1m, said in its response to the consultation last week that it was against the FPS, even with an exemption for its members.
Rogare has previously warned that the FPS could wipe £2bn off UK charities’ fundraising income in 2020.
Its response, which was compiled from its interpretation of the proposals with input from its 64-member advisory panel of practising fundraisers, says people who sign up to the FPS should be able to choose to receive communications from charities to which they have recently donated.
It says it accepts that the service will be set up but urges the working group to create options in addition to a "reset button" that would prevent all charity fundraising communications.
Its suggestions include enabling people to allow contact from charities to which they have made donations in the past two years, and allowing charities to which people donate on a regular basis to get in touch.
People should also be allowed to register only residential addresses with the service and not business addresses, because it might have "very serious consequences for corporate fundraising", the response says.
"At a stroke, some companies could ensure that charities could no longer make a cold approach about a corporate donation or partnership," it says.