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Charity Commission Updates Trustee Conflict of Interest Guidance After 23% Rise in Private Benefit Abuse Cases

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Summary

The Charity Commission published updated guidance CC29 for charity trustees on identifying and managing conflicts of interest, covering both financial conflicts and conflicts of loyalty. Research by the regulator found that compliance cases involving alleged abuse of charitable status for private benefit rose by 23% in a single year, with unmanaged trustee conflicts a recurring factor. The guidance is shorter and clearer, with common examples to help trustees recognize conflicts. The Commission warns that decisions made without properly managing conflicts may be legally invalid, potentially rendering trustees jointly liable for losses from their own resources.

“The Commission stresses that decisions made without properly managing a conflict of interest may be legally invalid, which may result in the charity losing money and the trustees being deemed jointly liable to cover the loss from their own money.”

Why this matters

Charity trustees should treat the refreshed CC29 guidance as a compliance benchmark. Even absent deliberate wrongdoing, the Commission's position that unmanaged conflicts may render decisions legally invalid and expose trustees to personal liability means that documenting conflict identification and management steps is now operationally critical. Trustees who have not recently reviewed their conflict-of-interest procedures should do so against the specific examples now provided in CC29.

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GovPing monitors UK Charity Commission for new courts & legal regulatory changes. Every update since tracking began is archived, classified, and available as free RSS or email alerts — 8 changes logged to date.

What changed

The Charity Commission has published refreshed guidance CC29 to help charity trustees identify and manage conflicts of interest, distinguishing between financial conflicts (where a trustee or connected person stands to gain money or other value) and conflicts of loyalty (where obligations to another person or organisation could influence judgement). The guidance was updated in response to a 23% year-on-year increase in compliance cases involving alleged abuse of charitable status for private benefit, with trustee conflicts identified as a recurring factor. The Commission emphasises that most unmanaged conflicts arise from lack of awareness rather than deliberate wrongdoing, and that decisions made without properly managing a conflict may be legally invalid. Affected charity trustees should review their conflict-of-interest policies against the refreshed CC29 guidance, ensure they can recognise conflicts when they arise, and document how conflicts are managed — failure to do so may result in trustees being deemed jointly liable to cover charity losses from their own funds.

Archived snapshot

Apr 23, 2026

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Press release

Unmanaged conflicts of interest increase risk of financial abuse in charities, regulator warns

The Charity Commission is today publishing updated guidance for charity trustees on conflicts of interest, with research by the regulator suggesting many trustees are unsure how to recognise a conflict.

From: The Charity Commission Published 22 April 2026

The redesigned guidance helps trustees identify and manage both financial conflicts – where a trustee or someone connected to them stands to gain money or other value – and conflicts of loyalty – where obligations to another person or organisation could influence a trustee’s judgement.

Cases involving unmanaged conflicts may be rising

It comes as figures reveal a sharp rise in cases of alleged private benefit abuse at charities, many linked to unmanaged conflicts of interest.

In its first ever Charity Sector Risk Assessment, published last year, the Commission found that compliance cases involving the alleged abuse of charitable status for private benefit rose had risen by almost a quarter (23%) in a single year. Figures to be published later this year suggest that the upward trend may be continuing.

Conflicts involving trustees and their private interests were a recurring factor in many of these cases, representing an ongoing risk to the public’s trust in the wider charity sector.

While the total number of relevant cases still represent a very small percentage of charities overall, the regulator is keen to help trustees mitigate against the risks of such problems occurring.

The report found that conflicts involving trustees and their private interests were a recurring factor in many of these cases, and represent an ongoing risk to the public’s trust in the wider charity sector.

The updated Charity Commission guidance for trustees, known as CC29, is intended to help trustees identify and manage conflicts of interest and, in doing so, protect their charities from harm.

Many trustees unaware of what constitutes a conflict

Analysis drawn from the Commission’s casework further suggests that most unmanaged conflicts of interest arise from or are facilitated by a lack of awareness, rather than deliberate wrongdoing.

Trustees, most of whom are volunteers, are often unable to identify a conflict when it arises and therefore fail to take steps to protect their charity’s assets or reputation.

This is confirmed in the Commission’s published research with trustees, which found that many trustees are unsure about how to recognise and deal with a conflict.

The updated guidance is shorter, clearer and includes common examples of situations in which a conflict of interest can arise in a charity.

Rachel Wenstone, Assistant Director of Policy at the Charity Commission, said:

The vast majority of trustees give their time freely and generously, and we want to give them clear, practical guidance to help them do their jobs well.

Our refreshed guidance will enable trustees to identify and manage conflicts of interest when these, to best protect themselves and their charities.

This matters -– the trust that the public place in charity can be shattered by the perception that some amongst those entrusted to protect a charity may be abusing it for personal gain.

Trustees who fail to manage conflicts of interest, even unintentionally, risk becoming part of that problem, and our guidance will help them to avoid this.
The Commission stresses that decisions made without properly managing a conflict of interest may be legally invalid, which may result in the charity losing money and the trustees being deemed jointly liable to cover the loss from their own money.

The Commission may also consider it as evidence of misconduct or mismanagement.

ENDS

Notes to editors

  1. The Charity Commission is the independent, non-ministerial government department that registers and regulates charities in England and Wales. Its ambition is to be an expert regulator that is fair, balanced, and independent so that charity can thrive. This ambition will help to create and sustain an environment where charities further build public trust and ultimately fulfil their essential role in enhancing lives and strengthening society. Find out more about the Charity Commission.
  2. The refreshed CC29 guidance is available at gov.uk
  3. The Charity Commission’s Charity Sector Risk Assessment 2025 is available at: Charity Sector Risk Assessment 2025 - GOV.UK
  4. The Commission’s research into  trusteeship can be found at: Research with trustees: 2025 - GOV.UK Press office

Email pressenquiries@charitycommission.gov.uk

Out of hours press office contact number: 07785 748787

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Last updated

Classification

Agency
Charity Commission
Published
April 22nd, 2026
Instrument
Notice
Branch
Executive
Legal weight
Non-binding
Stage
Final
Change scope
Substantive

Who this affects

Applies to
Nonprofits
Industry sector
9211 Government & Public Administration
Activity scope
Conflict of interest management Charity governance Trustee oversight
Geographic scope
United Kingdom GB

Taxonomy

Primary area
Corporate Governance
Operational domain
Compliance
Topics
Financial Services Civil Rights

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