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Charity Commission Funding Compliance Guide 2025: Essential Requirements for Grant Recipients

17 min read

Charity Commission compliance is essential for successful grant funding. This comprehensive guide covers regulatory requirements, reporting obligations, and best practices to ensure your charity maintains compliance while maximising funding opportunities in 2025.

Critical Compliance Alert - 2025 Changes:

New Requirements:

  • • Enhanced financial monitoring for grants over £25,000
  • • Mandatory cyber security assessments
  • • Digital-first reporting requirements
  • • Strengthened safeguarding obligations

Increased Penalties:

  • • Automatic funding suspensions for non-compliance
  • • Public inquiry triggers reduced
  • • Cross-funder information sharing
  • • Disqualification thresholds lowered

The regulatory landscape for charity funding has intensified significantly in 2025, with the Charity Commission implementing stricter compliance requirements and enhanced enforcement mechanisms. Understanding these requirements is not optional—it's essential for accessing and retaining grant funding.

Recent high-profile charity failures have led to increased scrutiny of grant recipients, making compliance excellence a competitive advantage in funding applications. Funders increasingly require evidence of robust governance and regulatory compliance before making awards.

Core Compliance Framework for Grant Recipients

Trustee Duties and Grant Management

Charity trustees bear legal responsibility for ensuring grant funds are used in accordance with charitable objects and funder requirements. This responsibility cannot be delegated, even to professional staff.

Fiduciary Duties

Trustees must act in the charity's best interests and ensure prudent management of resources.

  • • Exercise reasonable care and skill in decision-making
  • • Avoid conflicts of interest or declare them appropriately
  • • Ensure charitable funds are used only for charitable purposes
  • • Maintain appropriate oversight of grant expenditure

Due Diligence Requirements

Trustees must conduct appropriate due diligence before accepting grants and throughout project delivery.

  • • Verify funder legitimacy and grant terms compatibility
  • • Assess organisational capacity to deliver grant objectives
  • • Ensure grant activities align with charitable objects
  • • Establish appropriate monitoring and evaluation systems

Accountability Obligations

Trustees are accountable to beneficiaries, funders, and the public for the stewardship of charitable resources.

  • • Maintain accurate records of grant income and expenditure
  • • Provide regular reports to funders as required
  • • Ensure transparent communication about grant activities
  • • Submit timely returns to the Charity Commission

Financial Management and Reporting

Robust financial management systems are essential for compliance and form the foundation of funder confidence. The 2025 changes place additional emphasis on real-time financial monitoring.

Enhanced Financial Monitoring Requirements (2025)

For Grants Over £25,000:
  • Quarterly financial reports to funders showing grant expenditure against budget
  • Monthly management accounts available for inspection
  • Annual independent examination of grant-funded activities
  • Digital financial tracking systems with audit trails
For Grants Over £100,000:
  • Real-time financial monitoring with funder access to systems
  • Independent financial oversight through qualified finance committee
  • External audit requirement regardless of charity size
  • Risk management framework specific to grant delivery

Grant-Specific Compliance Obligations

Grant ValueCompliance RequirementsReporting FrequencyOversight Level
Under £10,000Basic financial records, annual returnsAnnualStandard
£10,000 - £25,000Detailed expenditure tracking, board oversightBi-annualEnhanced
£25,000 - £100,000Quarterly monitoring, independent examinationQuarterlyIntensive
Over £100,000Real-time monitoring, external audit, risk managementMonthlyMaximum

Safeguarding and Protection Requirements

Safeguarding requirements have been significantly strengthened in 2025, particularly for charities working with vulnerable groups or receiving public funding over £25,000.

Mandatory Safeguarding Framework

Policy and Procedure Requirements

Essential Policies:
  • • Safeguarding children and adults at risk
  • • Safer recruitment and DBS checking
  • • Whistleblowing and incident reporting
  • • Data protection and privacy
  • • Health and safety management
Implementation Requirements:
  • • Board-approved policies reviewed annually
  • • Staff and volunteer training programmes
  • • Clear reporting procedures and contact points
  • • Regular policy communication and updates
  • • Incident monitoring and reporting systems

New 2025 Requirements

Enhanced Due Diligence:
  • • Online safety assessments for digital services
  • • International background checks for overseas projects
  • • Continuous monitoring of staff and volunteer suitability
  • • Partnership due diligence for collaborative projects
Reporting Obligations:
  • • Annual safeguarding reports to Charity Commission
  • • Serious incident reporting within 24 hours
  • • Quarterly safeguarding audits for high-risk activities
  • • Cross-sector incident notification requirements

Digital Compliance and Cyber Security

2025 introduces mandatory cyber security requirements for charities receiving significant grant funding, reflecting increasing digital threats to the sector.

Cyber Security Obligations

Mandatory Requirements for Grants Over £50,000

Technical Controls:
  • • Multi-factor authentication on all systems
  • • Regular software updates and patches
  • • Encrypted data storage and transmission
  • • Firewall and antivirus protection
  • • Regular data backups and recovery testing
Governance Requirements:
  • • Board-approved cyber security policy
  • • Regular risk assessments and audits
  • • Incident response and recovery plans
  • • Staff training and awareness programmes
  • • Third-party supplier security assessments
Compliance Evidence:
  • • Annual cyber security certification
  • • Penetration testing reports
  • • Incident logs and response records
  • • Staff training completion certificates
  • • Supplier compliance attestations

Data Protection and Privacy

Grant activities often involve processing personal data, making GDPR compliance essential for both regulatory and funding requirements.

Data Protection Impact Assessments (DPIA)

Required for all grant projects processing sensitive personal data

Mandatory

Before project start

Privacy Notices and Consent

Clear information about data use with appropriate consent mechanisms

Essential

Before data collection

Data Sharing Agreements

Formal agreements required when sharing data with partners or funders

Required

Before sharing

Governance and Oversight Requirements

Board Governance Standards

Strong governance is increasingly viewed as essential for accessing significant grant funding, with funders requiring evidence of effective board oversight.

Board Composition Requirements

  • Minimum 3 trustees with relevant skills and experience
  • Chair and treasurer roles clearly defined and filled
  • Skills audit completed annually with gaps addressed
  • Diversity and inclusion considerations in recruitment
  • Succession planning for key governance positions
  • Conflict of interest register maintained and updated

Board Performance Standards

  • Regular meetings with documented decisions and actions
  • Strategic planning process with measurable objectives
  • Financial oversight including budget approval and monitoring
  • Risk management framework with regular review
  • Performance monitoring against charitable objectives
  • Annual governance review with external input

Internal Controls and Risk Management

Essential Internal Controls for Grant Recipients

Financial Controls:
  • • Segregation of duties in financial transactions
  • • Dual authorization for expenditure over set limits
  • • Regular bank reconciliations and independent review
  • • Annual independent examination or audit
  • • Budget monitoring with variance analysis
Operational Controls:
  • • Written procedures for key processes
  • • Regular monitoring of service delivery
  • • Quality assurance and evaluation systems
  • • Complaint and feedback mechanisms
  • • Document retention and management policies

Regulatory Reporting and Transparency

Charity Commission Reporting

The 2025 changes introduce enhanced reporting requirements with digital-first submissions and real-time monitoring capabilities.

Annual Returns Enhancement

New Required Information:
  • • Detailed breakdown of grant income sources
  • • Impact measurement data and outcomes achieved
  • • Safeguarding incident summary and actions taken
  • • Cyber security compliance certification
  • • Partnership and collaboration details
Digital Submission Requirements:
  • • Machine-readable financial data formats
  • • Digital signatures from all trustees
  • • Automated cross-checking with HMRC data
  • • Real-time validation and error checking
  • • Integration with funder reporting systems

Key Deadlines for 2025

Annual Return submission deadline:10 months after financial year end
Safeguarding annual report:31 January 2025
Cyber security certification:31 March 2025 (first submission)
Serious incident reporting:Within 24 hours of discovery

Public Transparency Requirements

Information TypePublication RequirementUpdate FrequencyAccessibility
Trustee InformationNames and roles on charity websiteWithin 30 days of changesPublicly accessible
Annual AccountsFull accounts on website and Charity CommissionAnnuallyPublicly accessible
Grant Impact ReportsSummary impact data on websiteAnnuallyAccessible format required
Safeguarding PolicyPolicy summary on websiteWhen updatedPublicly accessible

Compliance Risk Management

Common Compliance Failures and Prevention

Understanding common compliance failures helps organisations implement preventive measures and avoid regulatory sanctions.

High-Risk Compliance Areas

Financial Management:
  • Risk: Mixing restricted and unrestricted funds
  • Prevention: Separate accounting codes and regular reconciliation
  • Risk: Inadequate expenditure authorization
  • Prevention: Clear delegation limits and dual approval processes
Governance Failures:
  • Risk: Undeclared conflicts of interest
  • Prevention: Regular register updates and meeting declarations
  • Risk: Inadequate board oversight
  • Prevention: Structured reporting and regular performance reviews

Early Warning Indicators

Financial Red Flags:
  • • Unexplained budget variances over 10%
  • • Delayed financial reporting
  • • Cash flow difficulties
  • • Incomplete audit trail
Governance Issues:
  • • Frequent trustee resignations
  • • Poor meeting attendance
  • • Unresolved conflicts
  • • Lack of strategic planning
Operational Concerns:
  • • Increasing complaints
  • • Staff turnover spikes
  • • Service delivery problems
  • • Partner relationship breakdowns

Building a Compliance Culture

Organisational Compliance Framework

Successful compliance requires embedding regulatory awareness throughout the organisation, not just relying on senior management oversight.

Staff Training and Awareness

All staff should understand their role in maintaining compliance and the potential consequences of failures.

  • • Annual compliance training for all staff and volunteers
  • • Regular updates on regulatory changes
  • • Clear escalation procedures for compliance concerns
  • • Integration of compliance into induction programmes

Continuous Improvement

Compliance systems should evolve with changing requirements and organisational growth.

  • • Regular compliance audits and reviews
  • • Benchmarking against sector best practice
  • • Integration of lessons learned from incidents
  • • Technology upgrades to support compliance
"Compliance is not a burden to be managed, but a foundation for trust. Funders increasingly see strong compliance as an indicator of organisational capability and reliability." - Charity Commission Senior Regulatory Officer

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Risk Management
Early warning systems

Strengthen Your Compliance

Key Compliance Takeaways

Essential Compliance Actions for 2025:

  • Implement enhanced financial monitoring systems for all grants over £25,000
  • Complete mandatory cyber security assessments and implement required controls
  • Update safeguarding policies and procedures to meet strengthened requirements
  • Establish digital-first reporting capabilities for Charity Commission submissions
  • Strengthen board governance with annual reviews and skills audits

Charity Commission compliance in 2025 requires proactive management and continuous attention to evolving requirements. The organisations that excel in compliance will find themselves better positioned for funding success, with enhanced credibility and reduced regulatory risk.

Remember that compliance is not just about avoiding sanctions—it's about building the trust and credibility that funders seek when making significant grant awards. Strong compliance systems demonstrate organisational maturity and reliability, making your charity a preferred partner for funders seeking to maximise their impact.