Universal Church of the Kingdom of God (UCKG): February 2026

Name and type of organisation: Universal Church of the Kingdom of God (UCKG) (registered charity no. 1043985) 

Fundraising method:  Collection (private site - cash), Collection (public - cash)

Code themes examined: Pressure to donate, potentially vulnerable circumstances. 

Code breach? Yes   

The complaint   

The complainant told us that the charity Universal Church of the Kingdom of God (UCKG) solicited a large donation from her sister during her time as a member of the church. The complainant explained that her sister was vulnerable, having experienced problems with her mental health previously, and that her sister told her that this information was known to the charity at the time of the donation. 

In addition to this donation, the complainant also told us that her sister was frequently asked for donations towards charity activities while acting as a volunteer, as well as a 10% tithe for membership to the church. 

What happened?  

The Fundraising Regulator investigated a complaint about a large donation made by an individual. During the investigation we spoke to the donor who told us they were in vulnerable circumstances at the time they donated due to ongoing mental health problems. The complaint was that the charity was aware of those circumstances and should not have solicited the donation. The complaint also raised concerns about some of the charity’s broader fundraising practices. 

The charity described the donation as an “offering”, given as an expression of faith, and explained it did not consider this to be a charitable donation. We found it was a charitable donation and noted the charity claimed Gift Aid on this type of donation. 

We looked at how the charity considered the donor’s circumstances at the time they donated and if the charity had any training, procedures and policies that would help it identify the needs of potentially vulnerable donors and any support they may require when donating. 

We found the donor had made the charity aware of difficulties she had previously experienced with her mental health. The charity assumed the donor had moved past these difficulties and could therefore consent to the donation. It could not show that it had otherwise considered the donor’s needs or circumstances at the time the donation was made. We found the charity had breached the code. 

The charity did not have any training, procedures or policies in place regarding donors in vulnerable circumstances. These could have helped it objectively consider the donor’s needs and if they needed support when donating. 

Our decision  

Definition of donations 

The charity distinguished between its general fundraising and the offerings made during religious services or faith campaigns. UCKG stated that offerings were not considered charitable donations, as they are given as an expression of faith, rather than to support the charity’s operational needs. The charity explained that those who give often expect intervention in their lives because of making the offering. 

The Code of Fundraising Practice (the code) defines a donation as a voluntary gift of money or property that is voluntarily given and accepted without expecting or receiving something in return. We concluded that offerings, as described by UCKG, meet this definition. 

In this case donors may hope for or expect intervention by God in their lives by donating, however, it would only be a material benefit, not an expectation of faith or belief, that would exclude this type of giving from being defined as a charitable donation. 

No evidence was found to show that offerings were used other than to further the purpose of the charity itself, and UCKG acknowledged that it claims Gift Aid on this type of donation with the donor’s consent. 

Pressure to donate 

The complainant was concerned that the charity required members to give a 10% tithe, which she felt placed undue pressure on her sister. UCKG explained that tithing is a faith-based practice rooted in the Bible and forms part of its religious observance, rather than a compulsory payment members must make. Tithing is common among faith-based charities, and we recognised the complainant’s concerns, which are reflected in other complaints we receive about this method of fundraising. In this case, the amount and frequency of the tithe were voluntary, with no checks made or confirmation required by the charity. Therefore, we found no regulatory issues with this practice. 

The complainant was also concerned about their sister, as a volunteer, being asked to contribute financially to youth group activities. Although there was evidence that this type of fundraising occurred, there was insufficient information to conclude whether it breached the code. However, UCKG had not listed this as one of its fundraising methods and we recommended that the charity recognise it as such and ensure it complies with the relevant standards of the code. 

Considering the circumstances of the donor 

The charity explained that based on the donor’s active involvement with the church it considered she was wholly capable of making the decision to donate. We concluded that it was more likely than not that UCKG was aware of the donor’s previous mental health issues. The size of the donation was much greater than the donor’s usual giving. Despite this knowledge the charity failed to take appropriate steps to consider her capacity to donate or risk of vulnerability before accepting her donation. The charity lacked policies, procedures, or training for identifying and supporting potential donors in vulnerable circumstances, meaning it could not properly evaluate whether the donor was able to make an informed decision. Such consideration would have provided an opportunity for UCKG to check if its view of the donor’s capacity to decide to donate was correct. 

Risks associated with fundraising 

The charity encourages members to share public testimonies about past difficulties they have overcome. While this may be a positive experience, there are concerns that the charity has not fully considered the emotional impact such testimonies may have on both the speakers and those listening. 

Talking about past traumatic events can be distressing or triggering, potentially placing individuals in vulnerable circumstances, even temporarily. This vulnerability can also extend to those listening who may have had similar experiences. 

The charity advised us during the investigation that many of its members have experienced vulnerable circumstances as these are the people it seeks to include in its activities and membership. 

Since giving testimony and making offerings are linked in the charity’s campaigns, we consider that this type of fundraising activity has a higher risk. The risk was heightened in this case because the charity currently lacks systems to consider, identify or support donors who may be vulnerable. Recommendations have been made to help the charity meet the required standards for informing and treating donors fairly. 

Code sections considered: 

1.2. Asking for support

• Standard 1.2.1. Unable to make a determination

1.3. Informing donors and treating people fairly 

• Standard 1.3.7. Breach identified
• Standard 1.3.8. Breach identified
• Standard 1.3.9. Breach identified 

Our recommendations  

We recommended the charity  

• Recognise and identify how it solicits donations and consider its responsibilities under the code across all its fundraising activities to ensure it is legal, honest, open and respectful, and complies with the code. We asked that the charity provide us with the outcome of a review of what it considers to be its fundraising activities. 
   
• Urgently takes steps to compile and implement a comprehensive fundraising policy for donors who may be in vulnerable circumstances and implement training for its fundraisers in this area. This should apply to all those soliciting donations on behalf of the charity, and for all its fundraising activity. 
   
• In terms of the large donation, we found the charity in breach of the code as it did not give any consideration to the possibility the donor could be in vulnerable circumstances. Therefore, we recommend that the charity’s trustees consider whether it should refund any of the donor’s donations and explain their considerations in reaching their decision to the complainant. The charity may wish to seek professional advice to assist it in reaching a decision. If trustees decide to issue a refund, depending on the rationale for their decision, they may need authorisation from the Charity Commission for England and Wales. 
   
• We have explained why we consider accepting offerings as part of a campaign of faith, when individuals give testimony, to be high risk. We recommend that the charity consider what safeguards it needs to introduce to the way in which it carries out it’s fundraising to ensure that the risk is managed. The charity may wish to seek professional advice as to how this can be done. 

Outcome  

The charity accepts that it must make changes to their fundraising work and implement policies and procedures to comply with the Code of Fundraising Practice.