Stronger charities for a stronger society Contents

Chapter 5: Supporting sustainability


270.Fundraising practices have changed dramatically in recent years, as charities have sought to respond to the challenging financial environment and pressure to operate in a more business-like fashion. These developments have led to considerable attention and scrutiny. A cross-party review (the Etherington Review) of fundraising regulation was published in September 2015 and the House of Commons Public Administration and Constitutional Affairs Committee (PACAC) reported in 2016 on issues around fundraising. Both reports concluded that a new, more proactive fundraising regulator was required to tackle the problems that they identified and strengthen public trust and confidence in the sector.342

271.The new Fundraising Regulator was established in January 2016 and from July 2016 took over responsibility for fundraising regulation, complaints handling and adjudications from the Fundraising Standards Board, and the codes of fundraising practice from the Institute of Fundraising and Public Fundraising Association.343

272.As a result of these developments, we consciously chose not to focus on fundraising in our inquiry.344

273.The new regulator was, however, welcomed by a number of our witnesses.345 The British Heart Foundation, while supporting the new regulator, stressed that “instances of malpractice in charitable fundraising are by far the minority” and that “the implementation of stricter controls must not disproportionately constrict a charity’s ability to develop relationships with donors and raise funds to carry out its charitable aims.”346 Paul Stallard suggested that the high-profile stories relating to charity fundraising had occurred not from ill-intent but were “more to do with the inability of some to cope with the ever increasing size and scale of their operations.”347

274.We were told that it was important for the new regulator to strike the right balance between regulation and compliance, to allow fundraising to take place in a fair and consistent environment, and to be proportionate in its dealings with smaller charities.348 A common point of concern was the financial burden of funding the new regulator, with a number of our witnesses suggesting that it would fall disproportionately on medium-sized charities.349 The Fundraising Regulator has subsequently announced the introduction of a voluntary levy to be applied to all charities which spent £100,000 or more per year on fundraising.350 The levy will be charged at a varying rate, beginning at £150 per year for those charities which spend less than £150,000 a year on fundraising, and rising in stages to a maximum of £15,000 per year for those charities whose annual fundraising spend is more than £50 million a year.

275.We welcome the action that has been taken to address the concerns about fundraising practices in the charity sector. The new Fundraising Regulator has only recently been established and therefore we do not recommend that further changes are made to the regulatory landscape for the time being.

276.We are conscious of the concerns from the sector that the voluntary levy to fund the Regulator may be disproportionately burdensome for small- and medium-sized charities. We recommend that the new Fundraising Regulator continually monitors the impact of the levy, particularly on small- and medium-sized charities, and makes changes if appropriate.

Economic and tax policy

277.We heard a range of views about various elements of tax and economic policy, particularly relating to Gift Aid and Value Added Tax (VAT).351 Her Majesty’s Revenue & Customs (HMRC) estimated that charities received tax relief to the value of £3.67bn in 2015/16. The largest contributor to this figure was national non-domestic rate (business rate) relief, at £1.79bn, followed by Gift Aid payments at £1.26bn.352

278.The Charity Tax Group said that the Government’s efforts to simplify the eligibility requirements for Gift Aid in the Small Charitable Donations and Childcare Payments Act 2017 was a positive development,353 but a number of witnesses told us that there was still scope to simplify the rules on Gift Aid and improve take-up.354 We note that the recent legislation was a missed opportunity to do more to improve Gift Aid processes for charities.

279.The Charity Tax Group told us that: “Irrecoverable VAT (tax which charities cannot recover due to various special exempts and zero ratings that it receives) costs charities over £1 billion a year.”355 A number of witnesses argued for a change in the VAT regulations on buildings used for charitable purposes,356 while Cancer Research UK said that the VAT rules on shared facilities was a “significant disincentive to collaboration” between charities, including universities, and industry.357

280.We also heard from small charities that the increase in the National Living Wage (NLW) was a challenge for their operation. They told us that while businesses had been reassured that the cost of paying for the NLW would be counterbalanced by cuts to corporation tax, charities—which do not pay corporation tax—would have no such relief in relation to rising staff costs.358

281.The Church Army suggested that the Government should do more to promote payroll giving (the donation of money to charity directly from someone’s wages or pension without paying tax on it), in particular by extending payroll giving to more Government staff.359 The Minister for Civil Society, Rob Wilson MP, said that:

“I am writing to quite a few businesses, because there is a campaign going on at the moment to encourage more companies to offer payroll giving to their staff. At the moment, it raises about £130 million a year. It is an easy, simple and tax-efficient way to give, and I would like to encourage a lot more businesses to get involved in it. There is a big campaign going on at the moment.”360

He also said that not every government department currently offered payroll giving.361

282.It is imperative for the charity sector that tax policies and processes are structured to ensure that charities are able to maximise their income and that bureaucracy is kept to a minimum.

283.We welcome the Government’s changes to Gift Aid as part of the Small Charitable Donations and Childcare Payments Act 2017. We recommend that the Office for Civil Society works closely with Her Majesty’s Revenue & Customs (HMRC) to examine whether there are further changes that would help charities maximise the value of Gift Aid and minimise bureaucracy.

284.We recommend that the Office for Civil Society works with HMRC to ensure that the needs of charities are high on the agenda in relation to future changes to VAT and the National Living Wage.

285.We recommend that the Office for Civil Society works to improve significantly the awareness and availability of payroll giving by companies. In addition, there is no excuse for any Government department not offering payroll giving to their employees. The Government must set an example in this regard by ensuring that payroll giving is offered to staff as standard by all departments and executive agencies.

Support within the charity sector

286.There was strong support for more guidance, training and capacity building for charities on a wide range of subjects, including governance, finances, fundraising and organisational development. We also heard calls for better communication between the sector and local and national government.362 These are all functions that the various infrastructure bodies, or umbrella bodies, in the charity sector might be expected to play.

287.Seamus McAleavey from the Northern Ireland Council for Voluntary Action (NICVA) explained the types of support that they offered to charities:

“We do quite a lot across a broad range of topics, such as good governance; governance support, helping organisations with their governing documents and the like; providing information to them about what is going on in a very broad range of topics; and helping them face some of the realities of their situation. We provide quite a lot of training in niche areas such as management and leadership, to help people in organisations to do better whatever they are focused on.”363

288.We heard, however, that the availability of support for charities from these sources had diminished and that there had been a significant loss of support from local Councils for Voluntary Service (CVSs).364 CVSs are charities that offer a variety of services and support for local charities and voluntary groups in an area, such as training, or advice on funding.365 We also heard from Rural Community Councils, which perform similar roles and seek to support charities in rural areas with the distinct challenges they face.366 The small charities we heard from at our roundtable events suggested that infrastructure bodies were under the same pressure as other charities, and that while there were active CVSs in metropolitan areas such as London, Manchester and Cardiff, elsewhere they had declined or disappeared altogether.367 Other witnesses argued that there needed to be more support from local government for CVSs.368

289.At a national level, Karl Wilding from the NCVO said that there were too many infrastructure bodies in the sector.369 The NCVO’s data suggested that in 2013/14 there were 1,160 umbrella bodies, making up 0.7% of voluntary organisations.370 However, ACEVO and the Small Charities Coalition said there were valuable roles for infrastructure bodies representing different groups.371

290.Small charities in particular need access to timely advice and support, and infrastructure bodies play an invaluable role by providing guidance and services. As with charities themselves, they are diverse, and come in different sizes and have different focuses depending on their intended beneficiaries.

291.Infrastructure bodies must ensure that they work together effectively, both to ensure they survive and so that they can improve the services they offer charities. They should explore collaborative service models to raise awareness among charities of the support available, and improve the accessibility and coherence of this support.

Role of volunteers

292.The charity sector relies heavily on volunteers and many charities told us that they could not do their work without them.372 The Association of Volunteer Managers suggested that the economic benefit of volunteering could exceed £50 billion a year,373 while other witnesses highlighted the value of volunteers in community cohesion.374

293.Professor John Mohan told us that volunteering rates were high and had been fairly stable since the first reliable national studies in the early 1980s.375 He noted that there were significant variations in volunteering rates between different geographical areas and between different socio-economic groups, and that some analysis suggested that volunteering may have declined recently as a result of economic austerity. He said that:

“The implication was that adverse economic circumstances have detectable and relatively immediate effects on engagement, weakening the capacities of communities to cope.”376

294.Karl Wilding said that volunteering had changed in other ways in recent years:

“We have moved away from what you might call a substitute labour model, where people give 35 or 40 hours a week to the same organisation over the course of their life, to one that is much more flexible and footloose and is based on the idea of microvolunteering where people give relatively small amounts of time.”377

295.We also heard that younger people were placing greater importance on volunteering as part of gaining skills to help their employment prospects, a pattern one of our witnesses described as “self-interested altruism.”378 Community Southwark said that:

“Where once the main motivation for volunteers was around philanthropy, there are now more pressing motivations around gaining experience to find paid employment, isolation, creating new networks, supporting passions and interests.”379

296.Pilotlight suggested that an increase in young people volunteering might be linked to “an environment which allows for increased flexibility and digital engagement with volunteering.”380 The potential for digital technology to communicate with and mobilise supporters is discussed further in Chapter 6.

297.Lloyds Bank Foundation and the Small Charities Coalition both suggested that charities had become increasingly dependent on volunteers, in part due to funding cuts.381 The Foundation for Social Improvement said that volunteers were no longer just a “helping hand.”382

298.Karl Wilding suggested that the increasing use of volunteers had prompted charities to think about how they change their business models.383 Visionary argued that that an over-reliance on volunteers risked hindering the growth of a charity384 and Age UK Runnymede and Spelthorne noted that charities using volunteers to deliver services were at risk, as volunteers could not be compelled to work.385

299.We heard from some witnesses that volunteers were increasingly taking on professional responsibilities akin to those of employees and that this risked conflicts with professional staff.386 The Association of Volunteer Managers told us that:

“Volunteers play a significant and complementary role to paid professionals, but the boundaries between staff and volunteers are becoming increasingly blurred and we need to ensure that employment legislation and unions take this into account. Examples include Ambulance Service First Responders, Special Constables and individuals within communities voluntarily taking on the responsibility for running libraries.”387

300.Karl Wilding said that:

“all the evidence from the volunteer managers we work with tells us that volunteers do not want to replace paid staff in the sense that they do not want to put people out of jobs, but they absolutely recognise that they can contribute something to a service over and above what the paid staff delivering that service do.388

301.We heard from a number of small charities that to use volunteers effectively they need a volunteer manager, which costs money. They told us that finding funding for volunteer managers was particularly difficult,389 as the costs of volunteers in terms of terms of recruitment, training and management were not recognised by funders.390

302.Training and support for volunteers are all the more important if they are undertaking roles similar to or in place of paid staff.391 However charities, particularly smaller charities, have limited resources and capacity to provide for the development of their volunteers.

303.A number of our witnesses suggested there was a need for a fresh vision and drive behind volunteering. Matthew Taylor reflected that there might be an opportunity to rethink the place of volunteering in society given the changes taking place:

“How we think about a society where being a volunteer has the same status as being an employee, and it is an important part of how people feel they are fulfilled, develop and grow in their lives, is a big opportunity. We still kind of think that the big thing in your life is your work, and you then might do a bit of volunteering on the side. It may be that in 30 years it is reversed.”392

304.Karl Wilding said that:

“Volunteering and delivering services are compatible, but we need a clear vision about what the role of volunteering is, and we need to ensure that we adequately support volunteers in discharging the work they do.”393

305.And Professor John Mohan said:

“what is important is to consider the basis on which you appeal to people for more voluntary support. It needs to be a positive one, one that is not just about bailing out public services, and it needs to send a message that volunteers are not just a managed resource, but they are making a positive, independent contribution in their own right to an organisation.”394

306.In terms of practical suggestions, Martin Sime from the Scottish Council for Voluntary Organisations (SCVO) told us that there was a significant opportunity to increase volunteering through allowing unemployed people to volunteer without risking losing their benefits. He said:

“if you could persuade the DWP [Department for Work and Pensions] to remove all the barriers to unemployed people volunteering, you would do charities a great favour because we would be able to get a whole lot of people engaged in our work in a way that was good for them and good for us.”395

307.Lesley Michaelis suggested that organisations could provide incentives to encourage staff to volunteer, such as “extra holiday, extra training, and flexible hours” and they could reward staff that volunteer through appraisals and promotion criteria.396 The NCVO said that a new Access to Volunteering Fund, along the lines of a scheme piloted in 2009, could encourage more disabled people to become volunteers.397

308.The Minister, Rob Wilson MP, told us that one of his key priorities was increasing social action and volunteering.398 On 14 December 2016 he announced an independent review “to look at how to increase participation in full-time social action by young people.”399 He said that: “By helping others, young people can also transform their own lives. Full-time volunteering can provide meaning and purpose, as well as allowing young people to gain the skills they need to transition into full-time work or study.”400

309.Charities are the primary conduits for volunteering in the United Kingdom and as such they play a very valuable role in civil society. Charity law and policy should promote and support the role of volunteers, and constraints on volunteering should be reviewed and addressed.

310.Harnessing and maximising the efforts of volunteers is central to the principle and the practice of many charities, and comes with a cost. Volunteers may need managing, supporting and training. Investing in volunteers, where possible, is a way of respecting their contribution as well as increasing their value to the charity.

311.Funders need to be more receptive to requests for resources for volunteer managers and co-ordinators, especially where charities are able to demonstrate a strong potential volunteer base. We recommend that Government guidance on public sector grants and contracts is amended to reflect this and set a standard for other funders.

312.There is scope for further efforts by the Government to allow people to incorporate volunteering into their lives. We recommend that, in line with our earlier recommendation on trusteeship (see paragraph 107), the Office for Civil Society should work with other departments, the public sector and businesses to encourage greater flexibility for employees to take time off for charitable work.

313.The patterns of volunteering are changing. Younger people may be more likely to participate in one-off actions and digital volunteering rather than the traditional volunteering activities of older generations. There are, however, opportunities to encourage younger people to participate in more traditional volunteering, in order to boost their credentials for employment.

314.We welcome the Minister’s review of full-time volunteering by young people. This should be encouraged, by Government, by infrastructure bodies and by employers, with the caveat that volunteering should be a springboard to, not a substitute for, paid employment. Getting young people volunteering early in life may also have longer-term benefits by encouraging a future willingness to volunteer.

Expectations and trust

315.The expectations on charities have increased significantly in recent years. A greater level of scrutiny has been directed towards charities and greater accountability and transparency are expected of them. We discussed how charities can be more accountable and transparent in Chapter 3. Karl Wilding noted that:

“Charities are no different from all other institutions, in that they face a greater level of scrutiny over how they work. The fact that they do good in and of itself is no longer good enough. How they do that good is something that people are increasingly asking questions about.”401

316.Martin Sime from the SCVO told us that:

“we have come to understand that public trust is the cornerstone of sustainability. If there is such a thing as a sustainable charity, it is one that enjoys lots of support from the public.”402

317.ICSA suggested that there were greater expectations of charity leaders compared to other sectors, with the public more willing to voice moral judgments as to how charities are run.403 There is also a greater expectation from funders to demonstrate impact, which we discussed in Chapter 3.

318.The charity sector has recently experienced high profile failings in respect of fundraising and governance, as we noted in the introduction to this report. The Charity Commission said that its research into public trust and confidence in charities in 2016 had found a significant drop for the first time since they began tracking public trust in 2005.404 They noted that:

“Time will tell whether this is a long term trend or a short term dip but it is our view that both the leadership of the sector and the regulator should respond to this drop in confidence.”405

319.The picture is complicated. Dr Eddy Hogg told us that his research had found that people “on the whole trust charities” and “have high expectations of them.”406 Survey research by nfpSynergy in autumn 2016 found that charities had risen to being the fourth most trusted public institution after the NHS, schools and the armed forces. This was a rise from twelfth place a year before.407 On the other hand, Edelman’s 2017 trust barometer showed a small fall in trust in NGOs in the UK from the previous year,408 though the definitions of charities in each survey were not the same and they were therefore not directly comparable.

320.nfpSynergy suggested that:

“we need other measures of the health of the sector. For instance, the growth in income of different sizes of charities, levels of individual giving and volunteering, the number of new charities, and (perhaps most difficult of all) the differences that charities make.”409

321.We heard varying opinions on impacts that a loss of trust might have had on the sector.410 However a common theme was that the small number of high profile failures should not be allowed to tarnish the good work of charities more broadly. FaithAction said:

“We are concerned that the great work that many smaller charities do often goes unnoticed, unrecorded and unappreciated. Such organisations may do an excellent job but do not necessarily invest in making their work known; their work should still be championed.”411

322.Lord Hodgson of Astley Abbotts also emphasised that it was important not to forget the positives:

“It is very easy … to end up talking about the negatives. The charity sector does a lot of very, very good work and it is important that we keep it in perspective … we need to remember that there is a lot of good work going on there all the time.”412

323.Paul Stallard suggested that the Government should appoint a “charity tsar” to speak for the sector to help ameliorate trust issues.413 Mr Diarmuid McDonnell and Dr Alasdair Rutherford suggested that the Charity Commission might strengthen public trust and confidence in charities through greater transparency in its regulatory work.414

324.We believe that charities continue to enjoy a very positive public reputation—one of which other sectors would be envious—and are a highly valued part of public life.

325.That trust cannot be taken for granted, however, and charities should continue to be mindful of the impact of recent negative publicity, as well as of any indication that trust may be declining. The sector has learned hard lessons and charities need to be conscientious and scrupulous in order to retain that trust, maintaining their focus on transparency and accountability. We believe that the recommendations in this report will help them to do so.


326.The duplication of work by some charities was raised as an issue by some of our witnesses, who suggested that collaborations, partnership work and, where appropriate, mergers should be considered more frequently to improve the service they deliver to their beneficiaries. Matthew Taylor from the RSA told us that:

“charities are not as good at collaboration as they ought to be. There is too much of what Freud called “the narcissism of small differences”; charities that are, basically, around the same thing are competing with each other, when they would do much better to collaborate with each other or to merge.”415

327.Mencap noted that:

“There are many charities which occupy the same policy space and try to operate on the same problems. This … has implications for financial sustainability with a number of charities focused on raising support from a limited pool of donors. This could be addressed by closer co-operation or mergers.”416

328.The proposed revised Governance Code suggests that charity boards should undertake or oversee strategic reviews that should consider partnership working, merger or dissolution if other organisations are seen to be fulfilling similar charitable purposes more effectively.417

329.A number of witnesses gave examples of successful mergers.418 Family Action said that they had merged with Friendship Works “to make both organisations stronger by combining our talents and diversifying our service delivery.”419 Simon Prior-Palmer described the benefits of the merger of the two largest cancer research charities to form Cancer Research UK, and the collaboration and division of responsibilities between Cancer Research UK, Macmillan and Marie Curie.420

330.The Brain Tumour Charity said that the gradual consolidation of brain tumour charities over 20 years had “helped to enhance the scope of research, support, information and fundraising for the cause of helping people personally affected by a brain tumour and finding breakthroughs to tackle the disease.”421 They noted that despite the merger there were “over 50 charities for this purpose still in existence.”422

331.Some of our witnesses were more cautious about mergers. Lloyds Bank Foundation said that:

“not all mergers are successful and nor should small and medium-sized charities be forced to merge, as they have been in some situations. Other forms of partnership working can be more effective, whether formally or informally and the resources need to be available to facilitate this. It also needs to be recognised that in other cases, partnership working is not suitable and organisations should have the ability to remain autonomous.”423

332.Locality suggested that while mergers might appear to be a viable option, they were not necessarily a sustainable solution:

“These actions might build temporary sustainability but it often subverts purpose and can lead to mission drift in the longer term and potentially failure to meet original needs locally. This will therefore lead to the need for new grassroots organisations being set up in their place in order to address this unmet need.”424

333.Richard Jenkins from the Association of Charitable Foundations said:

“in my walk from Clapham to Stockwell, from the big supermarket to the place where I live in Stockwell, I pass four Sainsbury Locals. We could take a lesson from the private sector. Locally based, small high street organisations doing substantially similar things may not necessarily be a bad thing. It is the best way to be close to the beneficiary group you are trying to reach. I would be sceptical that merger is going to be the silver bullet. At the end of the day, charity is an expression of human passion, resourcefulness, a sense of injustice and the need to do something. You would not want to say to anyone that they should be doing that somewhere else.”425

334.We also heard about the risks and challenges of mergers between charities. The Wales Council for Voluntary Action noted that: “Mergers can be delicate and complex to navigate, and when charities fail can have severe consequences both on the services provided and the reputations and financial stability of the charities involved.”426

335.The Esmée Fairbairn Foundation detailed the barriers to successful mergers, ranging from liability issues, poor financial knowledge and management, high costs, and a lack of desire to merge.427 Gloucestershire Rural Community Council also suggested that the legal requirement for trustees to act in the interests of their own charity might discourage mergers even when conditions were right.428

336.Lord Hodgson of Astley Abbotts added that:

“One of the difficulties at present is that there are a number of technical problems that stop charities merging, such as, notably, legacies. If two charities merge and one charity disappears, under the present law, legacies left to that charity are voided. That cannot be what was intended. What was meant was that, if it is all done properly and all the boxes are ticked, those legacies should be valid.”429

337.We also heard that mergers were too often a last resort for charities. Both the Cranfield Trust and NAVCA noted that a “rescue” scenario was not desirable and a lot more difficult to manage successfully.430 Family Action said that the sector needed “to learn that not all mergers are a result of failure, and they should not be a last resort.”431

338.We heard that strong, effective governance and mutual understanding by both boards were essential to making mergers work.432 The Esmée Fairbairn Foundation said that, alongside governance and leadership, successful mergers occurred when organisations had a healthy financial forward plan, a positive approach to the merger, and time to consider all the options available. They added, however, that mergers often failed owing to disagreements over pension and lease liabilities as well as redundancy costs.433

339.Some of our witnesses suggested that the Charity Commission should increase support for mergers to help avoid duplication of effort in the charity sector.434 Kenneth Dibble noted that the Commission had historically had a mergers unit to help charities, though this had not undertaken proactive work and now no longer existed.435

340.The Office for Civil Society told us that:

“In relation to mergers the Government (and its predecessors) has put in place measures to encourage and support mergers, or make the process of merger simpler. However, anecdotal evidence suggests that many mergers in the charity sector arise as a result of the financial distress of one of the parties, and that relatively few mergers are strategically driven.”436

341.The WCVA said that for mergers to work it was important to have access to clear and accessible guidance and that charities needed to be “aware of the type of support that is available and how they can access it.”437 Lord Hodgson of Astley Abbotts pointed out that the Law Commission was preparing a technical Bill that would make a number of “quite technical but nevertheless important changes” to the law which should make it easier for charities to merge.438

342.We believe that mergers can often be considered a measure of success and maturity, and a reflection of a charity keeping a proper focus on its beneficiaries. Staff, trustees and volunteers should reflect upon the possibilities for mergers and consult with their beneficiaries where opportunities may exist. Mergers should not be seen as a sign of failure.

343.We note that it would be easier to avoid overlapping work in the charity sector by discouraging charities with similar purposes from being established where existing charities in the same field are working well and delivering for their beneficiaries. However, we would not want to discourage people from establishing new charities, which could be the effect of such a system. We also note that only the Charity Commission could realistically undertake such a task, but that the Commission currently has neither the structure nor the financial capacity to carry out this work.

344.We welcome the Law Commission’s work to address some of the legal and technical barriers to charities looking to merge. We recommend that the Government brings forward the Bill at the earliest opportunity.

345.We recommend that the Charity Commission, as part of its emphasis on enabling regulation, considers what support and guidance it can offer to charities seeking to merge, and provides signposts to help that may exist elsewhere. The Commission should take a positive approach to assisting charities that choose to merge and assist in removing any barriers that may exist, notably with regard to liabilities such as pension arrangements.


346.We heard that charity closures were more likely to occur when trustees fail to recognise the charity’s financial position until it is too late. The Office for Civil Society said that:

“Where trustees have an up-to-date grasp of the charity’s financial circumstances and plan ahead properly, it is usually possible to have a more orderly winding-up, including in some cases making provision for some of the charity’s services to transfer to another charity, or at least identify alternative provision for service-users.”439

347.We heard that charities should be required to maintain larger reserves in order to guard against disorderly closure,440 however we note that in the current economic environment such a suggestion would be unrealistic for many charities. Clinks said that charities they had surveyed were already at risk of using reserves at an unsustainable rate to maintain services.441 Localgiving said that 42% of the groups they had surveyed had used their reserves in the last 12 months.442 Voluntary Organisations’ Network North East (VONNE) said that only 43% of the charities they surveyed in the North East had reserves to last up to three months and 53% planned to or were likely to use reserves in the coming financial year.443 The Charity Finance Group said that 54% of charities reported in a survey that they could not increase their reserves, even if they wanted to do so.444

348.Academics from the Bristol Business School said that: “Compounding the challenge is the notion that holding reserves within the charity sector has been considered taboo by significant regularity bodies and advisors to the sector.”445

349.In some circumstances, closures may be the right option for charities. An example of this would be small foundations or memorial funds that have delivered on their objective and no longer have the resources to continue. The NCVO said that:

“Charities may naturally dissolve if their charitable purpose is achieved, or where the trustees decide their purpose can be best achieved by transferring assets to another organisation with similar objects.”446

350.Where such an outcome can be anticipated, it is preferable that the charity is set up with an expected time limit at its foundation, making it easier to close when the moment arrives. An example would be the Diana, Princess of Wales Memorial Fund that consciously chose to spend all its resources to fulfil its mission and closed in an orderly manner after 12 years of operation.447

351.Time-limited structures are a good option for ensuring that small charities such as memorial foundations are able to dissolve when they have delivered on their charitable objectives. A merged or closed charity does not necessarily mean a failed charity.

352.We recommend that the Charity Commission include options for time-limited structures in the model governing documents that they produce for charities, as such clauses would prompt new charities to consider their lifespan from their inception.

342 NCVO, Regulating Fundraising for the Future: Trust in charities, confidence in fundraising regulation, (September 2015): [accessed 14 March 2017] and Public Administration and Constitutional Affairs Committee, The 2015 charity fundraising controversy: lessons for trustees, the Charity Commission, and regulators (Third Report, Session 2015–16, HC 431)

343 Fundraising Regulator, ‘Homepage’: [accessed 14 March 2017]

344 We note that, during the course of our inquiry, the Information Commissioner fined two large charities for their misuse of data for fundraising purposes. Information Commissioner’s Office, ‘ICO investigation reveals how charities have been exploiting supporters’: [accessed 14 March 2017]

345 Written evidence from Battersea Dogs & Cats Home (CHA0143), MHA (CHA0124) and Save the Children (CHA0149)

346 Written evidence from British Heart Foundation (CHA0152)

347 Written evidence from Mr Paul Stallard (CHA0049)

348 Written evidence from British Heart Foundation (CHA0152) and Institute of Fundraising (CHA0119)

349 Written evidence from Action Against Hunger (CHA0078), Church Army (CHA0003), Church Mission Society (CHA0014), Health Poverty Action (CHA0037) and Together for Short Lives (CHA0144)

350 Fundraising Regulator, ‘Information & registration for fundraisers: Levy’: [accessed 14 March 2017]

351 In March 2017 the NCVO announced that it would establish an independent commission to review the charity tax system. ‘NCVO to establish independent commission to review charity tax system’, Civil Society News (1 March 2017): [accessed 14 March 2017]

352 HM Revenue & Customs, UK Charity Tax Relief Statistics 1990–91 to 2015–16 (June 2016): [accessed 14 March 2017]

353 Written evidence from Charity Tax Group (CHA0122)

354 Written evidence from Centre for Philanthropy, University of Kent (CHA0072), Hallé Concerts Society (CHA0045), Institute of Fundraising (CHA0119), National Council for Voluntary Organisations (CHA0148) and Wales Council for Voluntary Action (CHA0097)

355 Written evidence from Charity Finance Group (CHA0092)

356 Written evidence from Association of Medical Research Charities (CHA0151) and National Village and Community Halls Network (CHA0086)

357 Written evidence from Cancer Research UK (CHA0035)

358 Note of roundtable discussion in Cardiff, Appendix 8

359 Written evidence from Church Army (CHA0003)

360 Q 217 (Rob Wilson MP)

361 Ibid.

362 Written evidence from Lloyds Bank Foundation for England and Wales (CHA0031), NCVO (CHA0148) and Pilotlight (CHA0073)

363 Q 115 (Seamus McAleavey)

364 Q 36 (Richard Jenkins) and written evidence from Springboard Project (CHA0011) and VONNE (CHA0123)

365 The acronym CVS is also sometimes used as Centre for the Voluntary Sector, Council for the Voluntary Sector or Community Voluntary Services, though the organisation it describes is usually the same.

366 Written evidence from Action with Communities in Rural England (ACRE) (CHA0085), Gloucestershire Rural Community Council (CHA0069) and Rural Community Council of Essex (CHA0096)

367 Note of roundtable discussion in Westminster, Appendix 7, and note of roundtable discussion in Cardiff, Appendix 8

368 Written evidence from Bolton Community and Voluntary Services (CHA0064) and Young Barnet Foundation (CHA0101)

369 Q 16 (Karl Wilding)

370 NCVO, ‘UK Civil Society Almanac 2016: Scope Data’: [accessed 14 March 2017]

371 Q 16 (Asheem Singh and Rebecca Bunce)

372 Written evidence from British Red Cross (CHA0162), Charity Law and Policy Unit, School of Law and Social Justice, University of Liverpool (CHA0104), Clinks (CHA0084), Community Links Bromley (CHA0100), MHA (CHA0124), National Association for Voluntary and Community Action (CHA0076), RSM UK (CHA0120), RSPCA (CHA0070), Small Charities Coalition (CHA0140) and Together for Short Lives (CHA0144)

373 Written evidence from Association of Volunteer Managers (CHA0065)

374 Written evidence from British Red Cross (CHA0162), RSPCA (CHA0070), Rural Community Council of Essex (CHA0096), Stella Smith (CHA0060) and vInspired (CHA0118)

375 Q 92 (Professor John Mohan) and supplementary written evidence from Professor John Mohan (CHA0188)

376 Supplementary written evidence from Professor John Mohan (CHA0188)

377 Q 27 (Karl Wilding). A similar point was made in the written evidence from Carolyn Cordery (CHA0159).

378 Written evidence from The Brain Tumour Charity (CHA0145)

379 Written evidence from Community Southwark (CHA0075)

380 Written evidence from Pilotlight (CHA0073)

381 Written evidence from Lloyds Bank Foundation for England and Wales (CHA0031) and Small Charities Coalition (CHA0140)

382 Written evidence from Foundation for Social Improvement (CHA0057)

383 Q 15 (Karl Wilding)

384 Written evidence from Visionary (CHA0174)

385 Written evidence from Age UK Runnymede and Spelthorne (CHA0028)

386 Written evidence from Lord Hodgson of Astley Abbotts CBE (CHA0026)

387 Written evidence from Association of Volunteer Managers (CHA0065)

388 Q 27 (Karl Wilding)

389 Note of the Committee visit to Body & Soul, Appendix 4, and note of roundtable discussion in Cardiff, Appendix 8

390 Written evidence from Age UK Runnymede and Spelthorne (CHA0028)

391 Ibid.

392 45 (Matthew Taylor)

393 Q 27 (Karl Wilding)

394 92 (Professor John Mohan)

395 Q 123 (Martin Sime)

396 Written evidence from Lesley Michaelis (CHA0061)

397 Written evidence from National Council for Voluntary Organisations (CHA0148)

398 Q 210 (Rob Wilson MP)

399 Department for Culture, Media and Sport, ‘Call for more opportunities to support young people volunteering in the community’ (December 2016): [accessed 14 March 2017]

400 Ibid.

401 Q 15 (Karl Wilding)

402 Q 115 (Martin Sime)

403 Written evidence from ICSA: The Governance Institute (CHA0093)

404 Written evidence from Charity Commission for England and Wales (CHA0114)

405 Ibid.

406 Written evidence from Dr Eddy Hogg (CHA0134)

407 nfpSynergy, ‘nfpSynergy Trust in Charities Research — Autumn 2016 update’ (2 December 2016): [accessed 14 March 2017]

408 Edelman, ‘2017 Edelman Trust Barometer Global Report’: [accessed 14 March 2017]

409 nfpSynergy, ‘nfpSynergy Trust in Charities Research — Autumn 2016 update’ (2 December 2016): [accessed 14 March 2017]

410 44 (Matthew Taylor), Q 100 (Marged Griffiths) and written evidence from Clore Social Leadership (CHA0132) and Mr Elliot Harris (CHA0185)

411 Written evidence from FaithAction (CHA0015)

412 Q 96 (Lord Hodgson of Astley Abbotts CBE)

413 Written evidence from Mr Paul Stallard (CHA0049)

414 Written evidence from Mr Diarmuid McDonnell and Dr Alasdair Rutherford (CHA0023)

415 Q 48 (Matthew Taylor)

416 Written evidence from Royal Mencap Society (CHA0154). See also written evidence from Mr John Dale (CHA0005).

417 The Charity Governance Code Steering Group, Charity Governance Code Consultation document (November 2016) para 1.4.2: [accessed 14 March 2017]

418 Written evidence from Lloyds Bank Foundation for England and Wales (CHA0031) and True and Fair Foundation (CHA0138)

419 Written evidence from Family Action (CHA0135)

420 Written evidence from Mr Simon Prior-Palmer (CHA0187)

421 Written evidence from The Brain Tumour Charity (CHA0145)

422 Ibid.

423 Written evidence from Lloyds Bank Foundation for England and Wales (CHA0031)

424 Written evidence from Locality (CHA0133)

425 36 (Richard Jenkins)

426 Written evidence from Wales Council for Voluntary Action (CHA0097)

427 Written evidence from Esmée Fairbairn Foundation (CHA0044)

428 Written evidence from Gloucestershire Rural Community Council (CHA0069)

429 Q 95 (Lord Hodgson of Astley Abbotts CBE)

430 Written evidence from The Cranfield Trust (CHA0103) and National Association for Voluntary and Community Action (CHA0076)

431 Written evidence from Family Action (CHA0135)

432 Written evidence from Devon Air Ambulance Trust (CHA0083) and Wales Council for Voluntary Action (CHA0097)

433 Written evidence from Esmée Fairbairn Foundation (CHA0044)

434 Written evidence from Institute of Risk Management (CHA0039) and Tree of Hope (CHA0041)

435 Q 206 (Kenneth Dibble)

436 Supplementary written evidence from Office for Civil Society, Department for Culture, Media and Sport (CHA0165)

437 Written evidence from Wales Council for Voluntary Action (CHA0097)

438 Q 90, Q 95 (Lord Hodgson of Astley Abbotts CBE)

439 Supplementary written evidence from Office for Civil Society, Department for Culture, Media and Sport (CHA0165)

440 Written evidence from Mr Len Jones (CHA0004)

441 Written evidence from Clinks (CHA0084)

442 Written evidence from Localgiving (CHA0016)

443 Written evidence from VONNE (CHA0123)

444 Written evidence from Charity Finance Group (CHA0092)

445 Written evidence from Elizabeth Green, Dr Felix Ritchie, Dr Glenn Parry and Dr Peter Bradley (CHA0052)

446 Written evidence from National Council for Voluntary Organisations (CHA0148)

447 Other examples include The Tubney Charitable Trust, Giving our all: reflections of a spend out charity: [accessed 14 March 2017] and The Queen’s Trust, which is aiming to spend its remaining funds by 2020: [accessed 14 March 2017]

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