The Fundraising Regulator’s new Code of Fundraising Practice will be effective from 1 November 2025. But what are the requirements of the new Code, and what steps could your charity take to get ready?
What is the new Code of Fundraising Practice 2025?
The Code of Fundraising Practice has been under review since September 2022 and was subject to a three-stage consultation process with over 200 fundraising organisations. The Code replaces its 2019 version and is intended to reflect the sector’s changing landscape.
The new version of the Code considers the strides forward that have been made in technological enhancements, such as digital fundraising and virtual campaigns, for example, which are now the norm. Since the last Code, there has also been a shift in donor expectations for greater transparency, reflected by the Charity Commission’s Public Trust Report.
The new Code aims to enhance transparency, accountability and ethical standards in charitable fundraising and focuses on a principles-based approach (rather than the set of rules that were previously laid out). Fundraising organisations must take appropriate steps to protect fundraisers from harm and harassment while fundraising and ensure that fundraisers feel supported and can raise concerns.
What key changes have been made to the Code?
1. Streamlined and principles-based approach
Reduced length – the new Code is around 45% shorter than its predecessor, making it more streamlined and hopefully supporting you to more easily assess your compliance. This has been achieved by combining and streamlining related standards and requirements.
Simplified structure – the guidance moves away from detailed prescriptive rules to provide a holistic approach to charitable fundraising. This should provide you with more flexibility to do what’s right in principle.
Principles-based approach – the Code supports you to be pragmatic by allowing you to explain if you are not compliant. To help guide you, the Code stresses the importance of legal compliance and transparency when carrying out your fundraising activities.
2. Greater donor protection
Refund policies – fundraising organisations need to have clear policies on donation refunds and make sure that donors’ rights to refunds are adhered to.
Complaints Management – fundraising organisations must have a publicly available complaints procedure and processes to ensure complaints are reviewed thoroughly. Insights from complaints need to be used to improve fundraising practices.
3. Enhanced oversight over third-party fundraisers
Due diligence – fundraising organisations must carry out suitable due diligence on third-party fundraisers to ensure compliance with the Code.
Monitoring of subcontractors – fundraising organisations should oversee subcontracted fundraising activities. This includes ensuring fundraisers have sufficient training and that payment models do not support unethical practices. There is an awareness across the sector of the risks around commission-based models in particular, which have been known to encourage inappropriate behaviour.
4. Transparency in fundraising communications
Clear communication – fundraisers need to be transparent about their intentions when approaching potential donors and ensuring, where possible, that there has been no misinterpretation of any conversation or discussion. This is particularly important to secure trust.
5. Enhanced governance responsibilities
Accountability at Trustee Board level – the Code assigns explicit responsibility to the governing body for overseeing charitable fundraising activities, including those which are delegated to others. This includes seeking assurance about compliance with the Code and any guidance. The governing body should also review risks and ensure all reporting requirements to the Fundraising Regulator are met.
Donation refusals and returns - decisions to refuse or return donations need to be documented sufficiently and third-party fundraisers need to be aware of the policies for such decisions to ensure compliance.
Trustees have a duty to ensure that fundraising activities comply with the new Code. Given the changes, it is important to assess the extent of changes required to be made as soon as possible, so there is clear visibility around the level of resources required to meet any new requirements in time for the 1 November 2025 deadline.
The Fundraising Regulator is providing a series of webinars and events, alongside its Code Advice Service, to support charities to comply with the new Code.
Next steps for your charity to get ready
Understand the new Code
Read and digest the new streamlined, principles-based guidance.
Review your current fundraising activities and strategy
Review and assess your fundraising methods to identify any divergence with the new Code.
Make a plan
Set out the changes you need to make by the 1 November 2025 deadline and establish any resources you need to achieve the deadline.
Articulate your risk
Use your assessment to score the likelihood and impact of not meeting the deadline, to monitor this risk as part of your standard risk management practices. Align this to the risk appetite agreed with your trustees so that it gets the right level of attention from you.
Update relevant policies and procedures
Revisit fundraising policies and procedures as well as agreements with third-party fundraisers/agencies. Check you are happy with any explanations for non-compliance – would a third party also agree they are reasonable?
Deliver training
Train your staff and volunteers, with a focus on respectful donor engagement, transparency and ethical fundraising practices.
Seek assurance
Timetable your assessment to provide you with assurance about whether or not you are meeting the requirements of the new Code, or documenting a valid explanation.
Get in touch
For more information about how we can support you to assess your readiness to comply with the new Code of Fundraising Practice, please contact us.
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