The Fundraising Regulator’s new Code of Fundraising Practice (“2025 Code”) came into effect on 1 November 2025 and is the most significant update since the 2019 Code (“2019 Code”).
Trustees and senior charity leaders now need to understand not just what the 2025 Code says, but how to show that their fundraising decisions are fair, reasonable and aligned with good governance. The focus is on being able to evidence how and why decisions were made, not simply whether a list of rules was followed.
The new Code moves from a detailed rulebook to a more principles‑based approach. The new Code has fewer prescriptive requirements, but there is more emphasis on trustees demonstrating that their decisions are appropriate and proportionate in the context of their charity.
This will be a big change for organisations that are used to the step‑by‑step guidance offered in the 2019 Code. While there's no doubt it is a real shift, it is also a chance to ensure that fundraising genuinely reflects your charity’s values and risk appetite.
Why the new Code matters for your charity
The main change in the new Code is how the Fundraising Regulator will assess whether your charity has met the standards.
The emphasis is in the new Code is on your decision‑making processes rather than on strict procedural box‑ticking as it was in the 2019 Code.
What this mean in practice, is that if a complaint is investigated, you will be asked to explain why your chosen approach was “appropriate” and “proportionate” in your particular circumstances, and to show how that judgment was reached.
This moves core aspects of fundraising compliance firmly into the governance space, rather than something that can be left solely to the fundraising team. And, trustees who do not understand the shift to principles‑based regulation risk leaving their organisations exposed. However, with clear responsibilities, good records and sensible systems, the new regime is manageable and can strengthen confidence in your charity’s fundraising.
The key changes to the Fundraising Code
In the 2019 Code it set out detailed rules for almost every fundraising scenario, which many charities used as a checklist. By contrast, the 2025 Code strips back the volume of rules and instead uses concepts such as “appropriate”, “reasonable” and “proportionate” throughout.
This allows the same standard to apply to a small local charity and a large national organisation, but leaves it to each charity to work out what compliance looks like in practice.
The Code now includes examples of acceptable and unacceptable practice to help illustrate the principles. These examples are helpful signposts rather than exhaustive lists, so your charity will still need to think through how to apply the underlying principle in its own context and be ready to explain that reasoning if asked.
The 2025 Code is structured in three parts: standards that apply to all fundraising, standards for working with others, and standards for specific fundraising methods. Many of the detailed rules from the 2019 Code have been consolidated, simplified or moved into separate guidance notes. This should make the Code easier to navigate, but charities will need to look at both the main rules and the supporting material when updating policies.
For trustees, this new structure is a reminder to consider fundraising governance in three ways: what happens across all activity, how the charity works with partners and third parties, and what extra controls are needed for higher‑risk methods. A single, updated fundraising framework that reflects this structure will help keep oversight manageable and consistent.
Behaviour towards donors
The general behaviour standards have been brought together and strengthened. Instead of a narrow requirement to be “polite”, charities must now take “all reasonable steps” to ensure fundraising reflects positively not only on their own organisation but on the wider sector. This includes avoiding unreasonable intrusions into people’s privacy, not putting undue pressure on individuals, and stopping an interaction when someone clearly wishes to disengage.
The rules on misleading donors have also been tightened. Charities must not give the impression that donations will be used for a specific restricted purpose if they may in fact be used more widely, and when fundraising for a particular project or appeal they must explain what will happen if more or less than the target is raised.
Trustee responsibilities
The general duties on trustees in relation to fundraising have been consolidated into broader standards, but expectations are clearer. Trustees are required to oversee fundraising with reasonable care, which includes taking responsibility for activities carried out by staff, volunteers and third parties, following relevant regulatory guidance, ensuring data protection compliance and considering reputational risks.
There is now an explicit duty to protect fundraisers from harm and harassment, with processes needed for reporting and dealing with issues. Trustees must also respond constructively and within an appropriate timeframe to enquiries from the Fundraising Regulator, and ensure that fundraising partners understand and meet the same expectations where they act on the charity’s behalf.
The new Code explained
Due diligence and accepting donations
The due diligence requirements have been simplified but made more explicit. Charities must carry out due diligence that is “appropriate” and “proportionate to the size and nature of the donation”, recognising that what is necessary for a modest cash gift is very different from what is needed for a substantial or unusual contribution.
The Code recognises that formal checking may not be required for small, routine donations, however, for large or unexpected gifts or gifts that involve complex asset structures like cryptoassets more detailed scrunity will be justified.
One important point remains, refusing or returning donations remains an exceptional step, and charities are expected to record clearly how those decisions are reached.
Fundraising complaints procedures
Charities must have a clear, publicly available fundraising complaints procedure that frontline fundraisers can explain to donors. Where fundraising partners do not have a suitable procedure of their own, they must agree to follow the charity’s process. This ensures a consistent approach to complaints, regardless of who is carrying out the activity.
When complaints are made, charities are expected to investigate thoroughly and fairly, respond without undue delay, and use learning from complaints to improve future practice. There is also a requirement for a published procedure for staff and volunteers to raise concerns about fundraising, including how they will be protected from victimisation or harassment when they do so.
Paying fundraisers
The detailed provisions on commission rates, caps and performance‑related pay have been replaced by a single overarching principle. Charities must give “appropriate consideration” to how they pay fundraisers, including whether their arrangements are proportionate and aligned with the charity’s values and best interests. This is about thoughtful, documented judgment, not an open invitation to do anything that is convenient.
Guidance from the Fundraising Regulator explains factors that charities should weigh when deciding how to structure pay. Trustees and senior managers therefore have more flexibility than under the 2019 Code, but will need to be able to show that risks and perception have been considered when agreeing remuneration structures for fundraising staff and third‑party agencies.
Data protection
The majority of the detailed data protection rules have been removed from the 2025 Code. Istead, they have been replaced by signposting to the Information Commissioner’s Office (ICO) guidance. The Code recognises the ICO as the lead regulator, so charities are expected to follow ICO requirements directly rather than working from a re‑stated version in the fundraising rules.
However, two key principles remain explicit:
- Charities must not sell or share personal data for fundraising unless they have a lawful basis, typically consent, and where data is shared for fundraising, the ICO expects donors to be told who their details will be shared with.
- If legitimate interests is used as the lawful basis, the decision‑making and balancing test must be recorded in line with ICO expectations.
Processing donations
When processing donations, the rules on handling cash, cheques and card payments have been streamlined into clearer standards. Charities must have procedures for counting, recording and banking donations promptly, setting out who is responsible for each step and how oversight will work. These procedures should be proportionate but robust enough to protect both the charity and those handling funds.
The Code includes detailed provisions on sealed collection boxes, tills and floats have been combined, but the underlying principle remains that donations must be handled securely and fully accounted for. Trustees should expect to see simple, practical controls rather than unnecessary complexity, provided the overall system is sound.
Volunteers
There rules around volunteers makes the distinction between “in‑aid‑of” and “on‑behalf‑of” volunteers but have been simplified. Charities are required to provide training and support that is appropriate to the volunteer’s relationship with the organisation and the type of fundraising they are doing. “On‑behalf‑of” volunteers, who fundraise in the charity’s name, will generally need more structured guidance than “in‑aid‑of” supporters.
For on‑behalf‑of volunteers, training should cover legal and safe fundraising, handling donations, what must be included in fundraising materials and expected standards of behaviour.
In instances where a charity is aware of "in‑aid‑of" activity , the charity has to take all reasonable steps to ensure that the fundraiser correctly describes the activity as being “in aid of”. It's also important the fundraiser knows where to find information on safe and legal fundraising.
Vulnerable people and safeguarding
The new Code strengthens and clarifies requirements relating to people in vulnerable circumstances. Charities must give appropriate consideration to donors who may need extra care and support to make informed decisions, and must not accept or keep donations where they know, or have good reason to believe, that someone lacked capacity to give them.
Fundraisers are not expected to assess every individual’s capacity, but they should be alert to clear signs that someone may be unable to make an informed choice and respond accordingly. Safeguarding procedures should cover everyone involved in fundraising, including event organisers, participating children and young people, parents or guardians and all potential donors, especially where there are additional risks.
Working with professional fundraisers
The requirements for written agreements with professional fundraisers and commercial participators have been simplified but not relaxed. Charities must have appropriate written agreements in place with third‑party fundraisers (other than volunteers, where a formal agreement is optional), and those agreements must give the charity sufficient protection and control, including a clear right to end the arrangement to protect its reputation.
It is important to that that agreements have to address key elements such as the nature of the activity, timescales, payment arrangements, ownership of materials, confidentiality, expected standards of behaviour, complaints handling and sub‑contracting. Trustees should be satisfied that the contract supports compliance with the Code and allows the charity to intervene promptly if something goes wrong.
Solicitation statements
Rules on solicitation statements have been simplified but the underlying legal obligations remain. Professional fundraisers and commercial participators must still give clear, accurate and up‑to‑date information before donors commit money or share financial details. The required content of these statements is now set out in accompanying guidance rather than spelled out in the Code itself.
This change is designed to make the Code itself less cluttered while keeping the legal requirements visible and accessible. Charities should ensure that their contracts, scripts and materials reflect the guidance so that fundraisers can meet their obligations in practice.
Public collections
The behaviour standards for street and door‑to‑door collections have been consolidated, but familiar safeguards remain the same. The “three‑step rule” still applies:
- If you approach someone and they have not stopped within three steps, you must end the attempt to speak to them.
- Fundraisers must also avoid approaching people at clearly unsuitable moments, such as when they are in queues or visibly working.
- For door‑to‑door activity, fundraisers must not call at properties with “no cold‑callers” signs or in designated no‑cold‑calling zones and should only knock at the front door unless specifically invited to do otherwise.
The time‑of‑day limits are largely unchanged, with street collections generally expected to take place within defined daytime and early evening hours.
Fundraising communications
The rules on fundraising communications have been reorganised, but the core principles are familiar. Communications must not mislead donors by omitting important information, presenting facts inaccurately, using unclear language or exaggerating claims. Charities are expected to be open, honest and respectful in how they describe their work and the impact of donations.
When using case studies, charities must ensure they are representative of real situations and obtain clear, informed permission from anyone who can be identified. Where the person has died, reasonable steps must be taken to obtain appropriate consent from their estate before using their story in fundraising materials.
Telephone fundraising
Telephone fundraising remains subject to specific safeguards. Charities must not make fundraising calls to anyone under 16, must avoid calling after 9pm unless someone has explicitly agreed to a later call, and must not rely on randomly generated numbers. At the start of every call, fundraisers should check that it is a convenient time to speak and be clear that they are calling to ask for financial support.
The Code also limits the number of times a fundraiser can ask for a financial contribution during a single call. Paying attention to these details is not just about technical compliance; it directly affects how donors experience your charity and the level of trust they are likely to place in it.
Events and challenge fundraising
Rules on events have been simplified but still require a structured approach. Charities must carry out appropriate risk assessments, put in place suitable health and safety arrangements, and plan for foreseeable situations such as cancellations or significant changes. The level of formality should reflect the scale and risk of the event, but trustees should be confident that risks are being actively managed.
Participants must be told in advance about fundraising targets, age limits, fitness requirements and whether any of the funds raised will cover their own costs. Charities also need clear procedures for what happens if conditions are not met or if events are cancelled, including how sponsors will be informed and whether refunds are appropriate.
Legacies
Legacy fundraising rules have been consolidated, but the underlying standards are unchanged. Charities must respect the freedom of testators to provide for their families and others, and handle any sensitive personal circumstances with care. Fundraisers can explain the option of leaving a gift, but must avoid behaviour that could be seen as unduly influential, coercive or insensitive.
Fundraisers should keep records of meetings and communications with potential legators. Safeguards against personal benefit have been strengthened: fundraisers must not draft, or be directly involved in drafting, wills that benefit them personally, must report any offer of a personal legacy to the charity, and charities should have clear procedures for managing such situations.
Where donors pay for will‑writing services that include a legacy to the charity, requirements are more detailed. Charities must provide clear information about the service, give people at least two providers to choose from without recommending a particular firm, and make clear that the provider acts only in the testator’s interests.
What do charities need to do?
The move to a principles‑based Code calls for active trustee involvement rather than a passive reliance on detailed rules. The practical steps below will help charities get ready.
Review your fundraising policies
Many existing policies were drafted with the 2019 Code’s prescriptive rules in mind and are likely to need updating. This is more than a wording exercise: policies now need to explain how the charity will show that its approaches are “appropriate”, “reasonable” and “proportionate” for its size, activities and risk profile.
Document your decision‑making
The new Code expects charities to record key fundraising decisions and the reasoning behind them. This includes decisions about refusing or returning donations, the level of due diligence carried out and how payment arrangements for fundraisers have been judged to be appropriate. Good records will be crucial if the Fundraising Regulator ever reviews your activity.
Update your complaints procedures
Your fundraising complaints procedure should be easy to find, straightforward to explain and aligned with the new Code’s expectations on investigation, response times and learning. You should also review your internal process for staff and volunteers to raise concerns about fundraising, checking that it clearly explains how people will be protected from victimisation when they speak up.
Train your fundraising team
Teams need to understand the shift from detailed rules to high‑level principles. Staff and volunteers must feel confident applying those principles in real situations, which is likely to require more focused training than many charities have previously offered on the Code.
Review your third‑party agreements
If you work with professional fundraisers or commercial partners, revisit your contracts to ensure they reflect the new structure and expectations of the 2025 Code. Agreements should give adequate protection, embed the charity’s complaints and safeguarding standards, and allow the charity to end the relationship where necessary to protect its reputation.
Check your due diligence procedures
Due diligence processes for accepting donations should now be clearly risk‑based and proportionate. Make sure your procedures explain how different levels of checks will apply to different types and sizes of donations, and that decisions are being recorded consistently.
The same principle applies to due diligence on trustees, volunteers and third‑party fundraisers. The Code recognises that the nature and extent of checks should vary with the role and circumstances, so charities should be clear about when criminal record checks, references or other screening are appropriate.
Trustee training
Trustee understanding is now central to compliant fundraising governance. Every trustee should be familiar with the 2025 Code, the shift to principles‑based regulation and what this means for their oversight responsibilities. Without this, trustees cannot properly discharge their duty to oversee fundraising.
A focused board session on the new Code, using your charity’s real fundraising activities as examples, can be a practical way to embed this knowledge and test how you would demonstrate that your approaches are appropriate and proportionate.
A trust‑based approach
This move to principles‑based regulation marks the maturing of fundraising oversight in the UK.
For well‑governed charities, this brings more flexibility and less bureaucracy, balanced by a clearer expectation that decisions will be thought through and documented.
The 2025 Code represents a significant change, but it is ultimately a positive development: it assumes that charities, and their trustees, are capable of exercising good judgment and invites them to demonstrate that trust in how they fundraise.
FAQs
Most charities will need to review and update policies to ensure they align with the principles‑based 2025 Code rather than the detailed 2019 rules. Whether a full rewrite is required will depend on how heavily your existing policies rely on the old, prescriptive wording.
The new Code applies to fundraising activity from 1 November 2025 onwards. If the issue being investigated relates to activity before that date, the 2019 Code will continue to apply to that historic fundraising.
How do we prove something was “appropriate” or “proportionate”?
The key is to record your reasoning. When making fundraising decisions, note the factors considered, the options examined and why the chosen approach fits your charity’s circumstances, so that you can evidence this if needed.
No. The examples of acceptable and unacceptable practice are there to illustrate how the principles might apply in practice. They are not exhaustive, and different approaches may still comply if they meet the principle behind the rule.
Two charities can comply with the same rule in different ways, provided each can show that its approach is appropriate for its own context and risks. The regulator is looking for sound judgment and evidence, not uniformity.
No. The Code is primarily aimed at those governing and managing fundraising. Volunteers need training and support that is proportionate to their role, with “on‑behalf‑of” volunteers generally requiring more detailed guidance than “in‑aid‑of” supporters.
This information is for guidance purposes only and does not constitute legal advice. We recommend you seek legal advice before acting on any information given.
