Code 2025 frequently asked questions

The 2025 code has been updated to set clear standards in a different way from the 2019 code. Instead of listing detailed rules for every type of fundraising, the new code takes a principles-based approach. The result is a shorter, clearer code, with rules expressed as principles and supported by examples to show how they apply in practice. 

For example, one of the rules is: 

1.1.2 You must take all reasonable steps to make sure your fundraising is carried out in a way that reflects positively on fundraising in general. 

This includes: 

• not unreasonably intruding on a person’s privacy;
• not putting undue pressure on a person to donate;
• not using unreasonably persistent approaches; and
• accepting a request to end an interaction. 

The examples in the bullet points above are not intended to explain every behaviour which is permitted or prohibited. They help provide context on how your fundraising activity should reflect positively on fundraising in general. 

Regardless of the method, you should make sure that fundraising activity is not unreasonably intrusive, does not place undue pressure on people to donate, and is not unreasonably persistent. The requirement to end an interaction when asked applies in many contexts – for example, over the phone, face-to-face on the street, at a stall on a private site, or during door-to-door fundraising – so it does not need to be repeated in different sections of the code. In addition, the principle would apply to a range of other contexts not currently outlined in the code, for example if an artificial intelligence (AI) chatbot is speaking with a potential donor and they ask to end the interaction. 

The principles-based approach means the code does not need to list all practices that are always required or never allowed. Instead, it encourages fundraisers to think about how their activity meets the principles and allows them to consider how the principles in certain rules could apply to new and emerging fundraising approaches. 

The principles-based rules often include terms such as ‘appropriate’, ‘reasonable’ and ‘proportionate’, which fundraisers will need to interpret.  

For example, rule 2.2.2 in the 2025 code states that: 

You must carry out appropriate due diligence, proportionate to the size and nature of the donation, on the potential donor before accepting a donation. 

‘Appropriate’ and ‘proportionate’ due diligence will vary depending on the size and nature of the donation in relation to the charitable institution’s normal fundraising activity. It is often ‘appropriate’ and ‘proportionate’ not to carry out formal due diligence checks on small cash donations.  

For larger donations from known sources, some checks will be necessary, but these may be relatively straightforward. Unexpected large donations, or those which come in unusual forms such as loans, foreign currency or cryptoassets (such as Bitcoin), will require more complex checks. 

When we investigate complaints under the 2025 code, we will offer fundraisers a chance to explain how the steps they have taken are, for example, ‘appropriate’. We publish findings from our investigations to support sector learning. 

To help fundraisers decide what is ‘appropriate’ and ‘proportionate’, many of the new rules are also accompanied by examples of acceptable and unacceptable practices and additional guidance.

The code no longer contains rules which relate to specific legislation under the remit of another lead regulator – for example, lotteries regulated by the Gambling Commission or trustee legal responsibilities overseen by the Charity Commission. 

This change in approach means the majority of rules in Section 3 of the 2019 code – Processing personal data (information) – have been removed, as compliance with data protection legislation is the responsibility of the Information Commissioner’s Office (ICO).  

Rules relating to legislation have been removed in the 2025 code to avoid giving the impression that the Fundraising Regulator is the appropriate body to deal with these matters. However, we will continue to provide insights and summaries on fundraising-related issues, including data protection. This information will be flagged in the code with links to our website. 

Yes. Rule 2.1.5 requires that you must not sell or share a donor’s personal data without appropriate consent. However, if you have the appropriate consent or a legitimate interest in line with the ICO’s requirements, then you can share the data under those terms. 

You may not need to make significant changes to your fundraising practice to align with the 2025 code. Many of the requirements in the 2019 code are retained in the 2025 code but rules have been reframed for the principles-based approach.  

You should make sure that all your fundraising meets the expectations set out in Part 1 of the code (Standards which apply to all fundraising). If people outside your organisation are fundraising on your behalf, you should also consider the requirements in Part 2 (Standards which apply to working with others). When planning specific fundraising activities, you should meet the relevant rules in Part 3 (Standards which apply to particular fundraising methods). 

To help you adapt, you can use the table of changes, which maps the 2019 rules against the 2025 code. 

Finally, you should also read the code support guides, which set out our expectations in key areas such as monitoring fundraising partnerships, due diligence and documenting your fundraising decisions. 

Almost all donor protections from the 2019 code are retained in the 2025 code. The only minor exception is the removal of the expectation in rule 1.1.2 that fundraisers must be ‘polite at all times.’ This change avoids conflict with the new requirement (rule 2.1.2) that fundraisers can respond appropriately to harassment or inappropriate behaviour. 

Some protections for donors or restrictions on inappropriate practice have been clarified in the 2025 code, to address potential loopholes. For example, rule 8.4.3 of the 2019 code listed several types of stickers that indicate door-to-door fundraisers should not knock on a property. However, this created a risk that fundraisers might knock on doors which have signs that use different wording to state they do not wish to be disturbed. Under the 2025 code, rule 7.3.1 requires that fundraisers do not carry out door-to-door fundraising at ‘…properties where residents have made it clear they do not want to be disturbed’ and then further clarifies that this includes: ‘properties with a sign saying ‘no cold-callers’ or similar’. This ensures that fundraisers respect all clearly worded requests, regardless of the exact phrasing. 

Rule 2.4.1 does not specifically prohibit any payment approach for fundraisers, nor does it set out a specific baseline wage for fundraisers. The Fundraising Regulator’s Market inquiry into sub-contracting, conducted during the code review, found that charitable institutions can use commission or performance-based payments effectively and fairly. However, the new rule 2.4.1 requires that those who govern charitable institutions should give appropriate consideration to how the payment approach they use aligns with the values of the institution. 

Section 4 of the 2025 code outlines the specific rules that apply to volunteer fundraisers and explains how you should support ‘on-behalf-of' volunteer fundraisers (those you have instructed to fundraise for you). Some ‘in-aid-of' volunteer fundraisers may meet the definition of commercial participators and so will be subject to certain rules in Section 6 of the code. 

All fundraising activity under your control (including by ‘on-behalf-of' volunteers) are subject to the wider rules in the code, so you should make sure ‘on-behalf-of' volunteers follow the requirements in Part 1 (Standards which apply to all fundraising). You should also consider ‘on-behalf-of volunteers’ when planning fundraising activities which are covered in Part 3 (Standards which apply to specific fundraising methods). 

To help donors make an informed decision about what method they use to donate, you should include details of processing fees which are charged by a third-party providing fundraising services, such as tap-to-donate devices. You are not expected to quote standard processing fees such as a credit card transaction fee. 

‘Unstaffed collection’ is a new term in the 2025 code, intended to cover fundraising methods where the donor does not need to interact with a fundraiser. They include static collections, charity bags, and donation sites, such as clothing banks. 

The list of examples in the code is not intended to be exclusive, and the unstaffed collection rules may be applied to new methods of fundraising that emerge, even if they are not explicitly mentioned in the code. 

A collection tin being held by a fundraiser during public fundraising is not an unstaffed collection, as a fundraiser is present. However, clear information about the charitable institution and any specific cause you are fundraising for should still be available to donors in these circumstances. 

The governing body of a charitable institution (usually trustees, for registered charities) is ultimately responsible for fundraising activity carried out on their behalf. You should make sure that written agreements with third-parties make it clear how you expect them to comply with the code. 

The code does not contain rules specifically dedicated to AI. However, as with any fundraising activity under your control, fundraising conducted using AI is subject to the rules set out in the code, particularly those in Part 1 (Standards which apply to all fundraising). 

If you use AI to produce fundraising materials, you should also consider the rules in Section 8 (Fundraising communications and advertising), ensuring AI generated content does not mislead potential donors. 

Trustees and other governing bodies are ultimately responsible for fundraising activity carried out by or on behalf of the charitable institution. Section 2 of the code now makes these requirements clearer, with revised wording to clarify that the expectations also apply to all institutions conducting charitable, philanthropic or benevolent fundraising, such as Community Interest Companies (CICs). 

The rules in the code apply to all organisations carrying out charitable, philanthropic or benevolent fundraising. Many rules apply to fundraising on any scale, but some, such as requirements to conduct due diligence (2.2.2) or to monitor partners (6.3.1) use terms such as ‘appropriate’, ‘proportionate’, or ‘reasonable’.  

This clarifies the Fundraising Regulator’s recognition that different levels of due diligence checks or monitoring will be required depending on the scale and nature of the fundraising activities.  

For example, a smaller organisation conducting a large and complex new fundraising approach will still be expected to monitor this work effectively. Similarly, a small organisation which receives an unexpected large donation will still be expected to conduct appropriate due diligence checks on the donor. 

The Fundraising Regulator will continue to provide resources to support compliance with the code and has recently published new guidance on fundraising events, fundraising on social media, and online gaming and fundraising (in July) and cashless donations (in September).  

However, we do not provide best practice advice on topics such as written agreements or setting up a fundraising campaign. You may be able to find useful resources on these topics from wider sector and infrastructure bodies such as: 

• Chartered Institute of Fundraising
• NCVO
• Northern Ireland Council for Voluntary Action (NICVA)
• Scottish Council for Voluntary Organisations (SCVO)
• WCVA 

For specific questions about legal matters, you should seek advice through the lead regulators. Topics in this category include: 

• Gift Aid (HMRC)
• GDPR (ICO)
• Lotteries (Gambling Commission) 

If you have a specific question about complying with the code you can use the Code Advice Service. 

The 2025 code does not expand the scope of the Fundraising Regulator, but it does introduce some new areas of focus compared with the 2019 code: 

• Convenience Giving and Unstaffed Collections (section 7.5): sets out specific requirements for methods such as charity collection bins, tap-to-donate tools, and transaction round-ups.
• Rule 2.1.2: requires charitable institutions to take reasonable steps to protect fundraisers from harm and harassment.
• Rule 2.1.3: introduces a requirement to engage constructively with enquiries from the Fundraising Regulator about potential breaches of the code (see Engaging with the Fundraising Regulator for details).