The Charity Commission’s revised CC20: key changes for trustees

It’s ten years since the Charity Commission last revised its guidance Charity Fundraising: a guide to trustee duties (CC20). A change in charity law in 2016 was one of the drivers for that revision. The latest version reflects what the Charities Act 2022 says about fundraising, and its release coincides with the final provisions of the Act that came into force in October 2025. The revised guidance also takes into account November’s updated Code of Fundraising Practice.

What’s changed?

• The main changes to CC20 focus on offering more practical guidance for managing under- or over-funded appeals, in line with the Charities Act 2022 requirements.
• The guidance also places a stronger emphasis on reputational risk and on the board’s role in overseeing fundraising activity.
• In addition, it adopts a more simplified and accessible structure.
• The revised guidance also references contemporary issues such as:
  • the use of artificial intelligence in fundraising;
  • raising cryptocurrency donations, and
  • fundraiser well-being – none of which were addressed in the 2016 version.

Boards are now expected to maintain stronger oversight to avoid overreliance on delegated fundraising activity. Recent investigations by the Fundraising Regulator have highlighted that ultimate responsibility still rests with the board, even where charities use agencies to monitor fundraising compliance of subcontracted fundraisers. Overseeing fundraising activities carried out in a charity’s name remains a challenging but essential governance responsibility.

For these reasons, CC20 reinforces the importance of embedding ethical values within fundraising strategies and communications, and maintaining transparent, open dialogue with donors and the wider public.

It’s important that trustees revisit their charity’s fundraising policies to ensure they remain compliant in the evolving regulatory landscape. Our nonprofit advisory team understand the complexities of fundraising governance and can support trustees and their charity review their policies and practices in this area.

You can view the revised guidance on the GOV.UK website Charity fundraising: a guide to trustee duties (CC20).

Our nonprofit advisory team understands the complexities of fundraising governance and can support trustees and their charity in reviewing their policies and practices in this area. Please contact us for a no-obligation consultation.