Code of Fundraising Practice

1. What Is Code of Fundraising Practice?

The Code of Fundraising Practice is the UK’s standards framework for charitable fundraising. Maintained by the Fundraising Regulator, it defines expected conduct for charitable institutions and third-party fundraisers. It is a governance and ethical-practice framework—not a fundraising strategy, donor-segmentation model, or formula for maximizing donations.

For nonprofits and NGOs, the central management question is whether fundraising protects donors, honors representations about their gifts, and has effective oversight. Consultants can use the code to structure reviews of campaigns, donation handling, agency relationships, and donor-facing processes.

Jurisdiction matters. The code applies to charitable, philanthropic, and benevolent fundraising activity in the UK, including activity by organizations not registered with the Fundraising Regulator. The code itself is not legally binding and does not replace applicable law or professional legal advice.

2. Origin and Background

The standards were developed collectively by the UK fundraising community through the Institute of Fundraising and the Public Fundraising Association. There is no single individual creator. Following the 2015 review of fundraising regulation chaired by Sir Stuart Etherington, responsibility transferred to the Fundraising Regulator on July 7, 2016, supporting greater independence in fundraising regulation.

The current code took effect on November 1, 2025. This revision consolidated many detailed rules into broader principles, making the framework more adaptable to different organizational sizes and fundraising approaches. Its underlying purpose remains consistent: establishing clear expectations and protecting the relationship between fundraisers and the public.

3. How Code of Fundraising Practice Works

The code combines overarching behavioral expectations with standards relevant to particular organizations, relationships, and fundraising methods. Application starts by determining which rules cover the activity and who is responsible—not by assigning an overall ethics score. Each section explains whom its requirements address.

Four values anchor the framework:

• Legal: Fundraising must comply with applicable law.
• Open: Fundraisers should explain their processes clearly.
• Honest: Appeals must not mislead through inaccurate claims, omissions, or exaggeration.
• Respectful: Fundraisers must respect people, avoid undue pressure, and accept requests to end interactions.

The substantive standards are organized into three parts:

These parts are cumulative, not alternative classifications: an outsourced public appeal may involve all three.

For management purposes, translate applicable requirements into observable controls. A restricted appeal, for example, needs alignment between its wording and how donations are used. An agency relationship needs appropriate checks and oversight. The code supplies the standards; management designs proportionate processes and supporting evidence.

4. When to Use Code of Fundraising Practice

Use the code before launching an appeal, appointing a fundraising agency, introducing a donation channel, or changing donor communications. It also provides a reference point when investigating complaints or reviewing whether delegated fundraising remains appropriately controlled.

It is particularly powerful when responsibilities cross organizational boundaries. A campaign may involve fundraising staff, program teams, finance, volunteers, and external providers. Review the entire process rather than assuming that approval of the appeal also establishes safe donation handling or effective partner oversight.

Prepare appeal materials, donor-preference records, complaints, contracts, donation records, and relevant policies. Involve fundraising, finance, program delivery, data protection, and trustees. A workshop can identify concerns; meaningful assurance requires testing actual transactions and interactions.

Where trustee reporting and escalation are unclear, a focused board governance review can establish what management must report and which decisions require board attention.

The code is not a good standalone tool for forecasting income, choosing a funding mix, or measuring mission impact. Its conclusions become misleading when teams use outdated requirements, omit channels, or treat written policies as proof of consistent practice.

5. How to Apply Code of Fundraising Practice: Step-by-Step

The following is a practical management approach, not an official assessment methodology prescribed by the code.

1. Clarify the decision and scope.

   Define whether the review supports campaign approval, organization-wide assurance, or remediation. Specify jurisdictions, legal entities, channels, partners, and review period. Identify the executive sponsor and decisions requiring trustee involvement.

2. Gather evidence of actual practice.

   Collect scripts, appeal copy, donation-page screenshots, contracts, complaints, gift records, and procedures. Interview staff and volunteers. Follow sample donations from solicitation through receipt and allocation; do not rely exclusively on policy documents.

3. Define the units of analysis.

   Assess identifiable activities: a restricted appeal, telephone campaign, community collection, major-gift acceptance process, or platform relationship. Separate units where different organizations, methods, or requirements apply.

4. Map applicable requirements.

   Use the current code and its supporting guidance. Distinguish requirements applying to the charity from those applying to partners or platforms. Record statutory questions separately for qualified review; the code is not a complete legal checklist.

5. Build a requirements-and-controls register.

   For each applicable requirement, record the activity, evidence, observed gap, control owner, corrective action, and review date. Separate confirmed weaknesses from missing evidence. This register is an implementation aid, not a regulator-issued certification tool.

6. Interpret gaps and prioritize action.

   Consider potential donor harm, misleading representations, donation security, and ineffective oversight. Do not average serious failures into a reassuring overall score. Identify where activities should pause pending correction, and investigate causes rather than merely rewriting policies.

7. Translate findings into operating changes.

   Assign owners, deadlines, and verification tests. Changes may include campaign approvals, preference management, donation reconciliation, partner monitoring, complaint escalation, and training. Allocate resources to implementation—not just completion of the assessment.

8. Test scenarios, align stakeholders, and iterate.

   Test an oversubscribed appeal, an agency’s delayed preference update, or an unexpected major gift. Vary operating assumptions, not the obligation to meet applicable standards. Resolve interpretations with appropriate expertise, obtain executive alignment, and retest after changes.

Where weaknesses span several functions, the natural follow-on engagement is compliance operating-model design: establishing responsibilities, approval routes, evidence requirements, training, and ongoing assurance across fundraising operations.

6. Example: Code of Fundraising Practice in Action

Fictional example: HarborBridge Family Support is a UK charity financing emergency family grants through individual donations, community events, and major gifts. Before expanding its winter appeal, trustees request a review of fundraising conduct and controls.

The team chooses three units of analysis: the restricted online appeal, an outsourced telephone campaign, and major-gift acceptance. It reviews appeal wording, donor-preference records, agency agreements, complaints, gift documentation, and finance allocations.

The review identifies two weaknesses. The appeal describes a specific grant program without explaining what happens if it raises too much or too little. Separately, telephone requests to stop contact are recorded by the agency but are not consistently reflected in the charity’s central records.

The insight is organizational: the fundraising team controls messaging, the agency controls interactions, and finance controls allocation, but no one checks the complete donor experience.

Trustees approve expansion only after corrective testing. Management clarifies the appeal’s purpose and contingency wording, fixes preference transfers, introduces campaign sign-off, and assigns an owner to verify gift allocation. Subsequent reporting pairs net fundraising income with complaints, preference failures, and unresolved control gaps. The code structures the standards review; management converts the findings into accountable operating changes.

7. Strengths and Limitations

Strengths

• Clear expectations: The code gives boards and fundraising teams a shared reference for acceptable conduct.
• Coverage across boundaries: Its standards address both charitable institutions and relevant third parties.
• Proportionate application: The principles-based approach allows controls suited to the size and nature of fundraising activity.
• Actionable review: Mapping standards to evidence can expose failures between solicitation, donor service, and donation processing.

Limitations

The code is not an exhaustive statement of law, and requirements must be interpreted for the relevant activity and jurisdiction. Principles also require judgment: reasonable action in one setting may be insufficient in another.

It does not establish the best fundraising portfolio or prove that a charity delivers meaningful outcomes. Compliance should be treated as a necessary safeguard, not a substitute for strategy, impact evaluation, or financial stewardship. A completed register is useful only if its controls operate in practice.

8. Common Pitfalls and How to Avoid Them

• Confusing standards with law: The code does not replace legislation. Maintain a separate record of legal requirements and obtain appropriate advice.
• Checking policies, not behavior: Approved procedures can conceal operational failures. Test donations, contact requests, reconciliations, and complaint handling.
• Delegating away accountability: Outsourcing fundraising does not remove governing-body responsibility. Establish reporting, monitoring, and escalation arrangements.
• Ignoring appeal contingencies: Specific-purpose appeals must explain what happens if funding exceeds or falls short of the target. Resolve this before launch.
• Using simplistic vulnerability labels: Avoid turning donor protection into demographic assumptions. Train fundraisers to recognize concerning circumstances and seek appropriate guidance.
• Rewarding income alone: Include conduct and control measures in management reviews so revenue targets do not obscure donor harm or unresolved failures.

9. How Code of Fundraising Practice Relates to Other Frameworks

Donor Bill of Rights

The Donor Bill of Rights emphasizes donors’ expectations concerning information, gift purpose, recognition, confidentiality, and professional relationships. Use it alongside the code when designing stewardship experiences; use the code to determine applicable UK fundraising standards. Neither substitutes for local law.

RACI responsibility matrix

A Responsible, Accountable, Consulted, and Informed (RACI) matrix clarifies stakeholder involvement. Apply it after identifying code-related gaps to assign campaign approval, partner monitoring, donation reconciliation, and complaint responsibilities. It helps establish ownership but does not determine acceptable fundraising conduct.

COSO Internal Control—Integrated Framework

The Committee of Sponsoring Organizations of the Treadway Commission’s framework supports broader internal-control design and evaluation. Use the fundraising code first to identify conduct expectations, then apply internal-control thinking to strengthen control activities, communication, and monitoring. Prefer this broader framework when assurance extends beyond fundraising into organization-wide operations and reporting.

10. Key Takeaways

• The code establishes UK fundraising standards, not a revenue-growth strategy.
• Determine applicable requirements by activity, organization, relationship, and method.
• Review the complete process from appeal to donation allocation.
• Turn findings into owned controls, tested changes, and continuing oversight.
• Do not confuse policy completion, code compliance, and compliance with law.

11. FAQs About Code of Fundraising Practice

Does the code apply to U.S. nonprofits?

It applies to fundraising activity in the UK, not automatically to U.S.-only activity. U.S. nonprofits may use it as a voluntary benchmark, while separately assessing local law and relevant professional standards, including the Association of Fundraising Professionals’ member code.

Is the Code of Fundraising Practice legally binding?

The code itself is not legally binding. However, fundraising activities remain subject to applicable law, and the Fundraising Regulator uses the code when considering fundraising complaints. Meeting the code is not comprehensive legal assurance.

Can a small nonprofit use the code effectively?

Yes. Start with the activities you actually undertake and design proportionate controls. Keep ownership and evidence straightforward, but do not interpret limited resources as permission to ignore applicable requirements.

What evidence is needed for a useful review?

Bring current appeals, scripts, donation records, complaints, partner agreements, preferences, and procedures. Add samples showing how these processes operate. The essential question is not whether a policy exists, but whether donors are treated and donations handled as intended.