Charity CommissionThe essential trustee (CC3, updated 16 September 2026) and the Commission's view on AI
→Trustees can delegate day-to-day work but not responsibility. The Commission hasn't issued AI-specific guidance; it expects trustees to apply their existing duties, not to rely on AI output for important decisions without reasonable independent checks, and to consider an internal AI policy. The trustees approve the charity's AI policy, and a named person, not the tool, approves each bid.
Charity CommissionCharity fundraising (CC20, revised 3 February 2026)
→The revised guidance covers trustees' oversight of fundraising, including grant fundraising and the use of AI, and how it fits with managing fraud and other risks. Report the AI-assisted process to the board like any other fundraising change.
Fundraising RegulatorCode of Fundraising Practice (in effect 1 November 2025) and its AI guidance (December 2025)
→Fundraising must be legal, open, honest and respectful, must not mislead, and needs appropriate evidence for claims. Grant applications must be prepared responsibly, and changes to how a grant is spent need the funder's written permission. Case studies must reflect real situations, say if details were changed, and have the person's clear and informed permission. The regulator's AI guidance asks for a person to check accuracy and fairness before use.
FundersEach funder's terms, including any rules on AI
→Funders' rules vary and change. UKRI's policy (September 2024), for example, lets applicants use generative AI with care, asks them to declare substantive use, rules out AI writing whole applications or sections without human involvement, and makes applicants responsible for anything falsified, fabricated or misrepresented. Other funders ask for declarations, discourage AI, or say nothing. The fit check reads each funder's current rules before drafting starts.
Cabinet OfficeGrants functional standard (GovS 015), grant agreements and the Procurement Act 2023 boundary
→Statutory funders must assess fraud risk and do due diligence on every scheme. The government's model grant funding agreement makes materially misleading or inaccurate information in an application an event of default. If a 'grant' is really a contract for services, it is a procurement, and supplying misleading information is an exclusion ground under the Procurement Act 2023. The library records which is which, as the annual return asks for government grants and contracts separately.
Home OfficeFraud Act 2006 and failure to prevent fraud (Economic Crime and Corporate Transparency Act 2023, in force 1 September 2025)
→A knowingly false statement to win a grant can be fraud by false representation. The corporate offence applies to large incorporated bodies meeting two of three tests (over 250 staff, over £36 million turnover, over £18 million assets), including large charitable companies, unless they had reasonable prevention procedures. A mid-sized charity may be below the thresholds, but the evidence check and sign-off log are good practice either way.
ICOUK GDPR and the Data Protection Act 2018
→Case studies, outcomes data and staff CVs are personal data, and stories about service users often touch special category data. Only consented, minimised case studies enter the library, consent records travel with them, personal details are checked before indexing, processing stays in UK regions, and the contract stops providers training their models on the charity's data.