The 2025 Charity Governance Code: What Small Charities Should Review

The 2025 Charity Governance Code is useful because it gives trustees a current benchmark for how a well-run charity should think, decide and evidence its governance. It is also easy to mis-sell. The Code is voluntary. It is not charity law, and it does not replace regulator guidance or your trustees' legal duties.

That distinction matters. A small charity does not need panic copy about "compliance with the Code". It needs a calm review of what its board already has, what is missing, and what should be adapted before trustees adopt it.

Start With The Correct Status

The Code is produced by a cross-sector steering group. It sets out principles and suggested evidence of good governance. Charity law and regulator guidance tell trustees what they must do.

For trustees, the practical use is this:

• Use the Code as a board-review benchmark.
• Use Charity Commission, OSCR, CCNI, Companies House, CIC Regulator, ICO and other official guidance for legal and regulatory duties.
• Record the board's decisions, especially where a policy is high-risk or activity-specific.

What The 2025 Code Means For A Policy Folder

The refreshed Code has eight principles. For a small charity policy review, the most useful question is not "do we have a document for every possible topic?" It is "can we show that our board has thought about the right risks for our activities?"

The Code's managing resources and risk principle includes suggested evidence such as financial policies and procedures, internal controls, reserves policy, staff and volunteer policies where relevant, a policy for technology and AI tools, fundraising policy where applicable, anti-fraud or anti-bribery controls, whistleblowing, a risk framework/register, and a social media policy.

That does not make every item legally mandatory for every charity. It does show why older or inconsistent folders deserve review.

A Practical Review Order

1. List what you already hold. Include policy name, owner, adopted date, last reviewed date and next review date.
2. Confirm what applies to your charity. Activities matter: working with children or adults at risk, holding personal data, employing staff, running events, handling restricted funds, fundraising, using AI tools, or holding investments can all change the policy set.
3. Prioritise high-risk topics. Safeguarding, data protection, financial controls, conflicts, reserves and risk management normally deserve early attention.
4. Add a technology and AI use policy where relevant. Keep it proportionate. It can start as a short board-approved statement on approved tools, personal data, human review, transparency and accountability.
5. Minute adoption. A template in a folder is not the same as an adopted board policy.
6. Get specialist review where needed. Safeguarding, data protection, employment, health and safety, regulated fundraising and financial controls can need qualified advice.

What About Funders?

Funders often ask whether an applicant holds appropriate, current policies. The exact requirement varies by funder, programme and activity. Do not assume a universal review window. Check the application guidance and keep a one-page register ready so the answer is clear.

A useful register includes:

• policy name
• version
• board adoption date
• next review date
• owner
• reviewer or minute reference

That one page helps a trustee, adviser or funder understand the status of the governance folder without reading every policy first.

A Faster Starting Point

The Charity Governance Pack is an editable starting suite for trustee review. It includes 16 policy templates, a policy-priority selector, a due-diligence register, trustee induction notes and working registers for adoption, conflicts and risk.

It is aligned with the voluntary 2025 Charity Governance Code and public regulator guidance reviewed on 19 June 2026. It does not guarantee compliance, funding or regulator acceptance. Trustees must adapt it to their organisation, get suitable review where needed, and formally adopt policies before relying on them.

Start with the free Governance Gap Finder if you want to see which parts of the folder may need attention before buying anything: Run the gap finder.

---

This article is general guidance for UK charities and CICs. It is not legal, regulated, accountancy or financial advice and it does not guarantee compliance with any regulator or funder. Verify the current position for your charity before adopting any policy.