What you need to know
It is the first time CC20 has been updated in a decade, and the timing is not coincidental. This is interconnected with the new version of the Fundraising Code of Practice and needs to be read together: the new Code of Fundraising Practice, which came into force on 1 November 2025 after a two-year review, and the updated CC20 – the Charity Commission’s guide to trustee duties on fundraising – which was revised on 3 February 2026. The two documents are now designed to work as a system, with CC20 explicitly signposting to the new Code throughout.
The headline change in the Code is the shift from a detailed rulebook to a principles-based approach. The new Code is 45% shorter than its 2019 predecessor. Prescriptive rules covering almost every fundraising scenario have been replaced by broader principles built around four foundations: legal, open, honest, and respectful. Data protection rules have been largely removed from the Code itself and replaced with signposting to the ICO, reflecting a sensible clarification of who the lead regulator is in each area.
CC20’s most substantive change is practical guidance on failed and over-funded appeals – now updated in line with the Charities Act 2022. The revised guidance also places noticeably stronger emphasis on the board’s role in overseeing and not simply delegating fundraising activity, and it explicitly references the use of artificial intelligence in fundraising for the first time.
What this means in practice
The principles-based shift in the Code is the change most likely to catch boards out, because it moves compliance from a checklist exercise to a judgement and documentation exercise. Under the 2019 Code, a charity could point to a specific rule and show it had followed it. Under the 2025 Code, the question the Fundraising Regulator will ask is not just “did you follow the rule?” but “can you show us why you made this fundraising decision and why it was appropriate, reasonable and proportionate for your charity’s context?” That is a materially higher bar, and it has direct implications for how your board minutes, policies, and risk assessments are written.
Three things boards should do in response to these updates, in order of urgency:
First, review your fundraising policy, then materials and pages against the new Code if you have not already. The transition period has ended. The 2025 Code now applies to all fundraising activity from 1 November 2025 onwards, and the Fundraising Regulator will use it when investigating any complaints received after that date. If your materials still reference the 2019 Code, it needs updating.
Second, strengthen your documentation of fundraising decisions. The new Code explicitly requires charities to be able to demonstrate their reasoning, not just their compliance. That means board minutes and policies that record not just what was decided about a fundraising approach but why – what risks were considered, what alternatives were examined, how the decision aligns with the charity’s values and the Code’s principles. If your board is used to recording decisions without recording reasoning, this needs to change.
Third, use CC20’s updated framework as the basis for your next board conversation about fundraising oversight. The six principles CC20 sets out for trustees – which include supervising fundraising rather than simply delegating it, protecting the charity’s reputation, and being transparent about commercial relationships – are a useful agenda framework in their own right. If your board has not actively discussed fundraising governance in the last twelve months, these updates are a prompt to do so, and quickly.
My take
A decade between updates to CC20 is a long time. Fundraising has changed enormously since 2016 – social media, online platforms, AI-generated content, the rise of peer-to-peer fundraising – and the guidance has been overdue a refresh. The principles-based approach in the new Code is broadly the right direction, because it avoids the problem of regulation perpetually lagging behind practice. But it does place a genuine additional burden on smaller charities and volunteer-run boards who previously relied on the old Code as a checklist. They now need to exercise judgment and document that judgment, which requires a level of governance infrastructure – policies, minutes, a functioning risk framework – that many smaller organisations are still building.
The recent Stoke Air Ambulance case is worth keeping in mind as a reminder of why fundraising governance matters at the most fundamental level. That charity misled donors about its operational capacity, and the reputational damage was severe. Fundraising is where public trust in charities is arguably most directly tested, and the board’s oversight role in that space is not optional or peripheral – it sits at the heart of what trustees are there for.
Both documents should be read as a priority. The new Code of Fundraising Practice is available in full on the Fundraising Regulator’s website, and the updated CC20 is on GOV.UK. The Fundraising Regulator has also published three practical support guides on due diligence, documenting decisions, and monitoring fundraising partners – these are worth sharing with whoever manages fundraising in your organisation.
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