Article
Fundraising Regulator issues guidance for donors in vulnerable circumstances
2 February 2026 | Applicable law: England and Wales | 2 minute read
Fundraising Regulator issues guidance for donors in vulnerable circumstances
The Fundraising Regulator has issued guidance for charities and fundraisers in engaging appropriately with donors who may be experiencing vulnerable circumstances. The guidance is intended to support organisations in meeting the requirements set out in the Code of Fundraising Practice.
Vulnerable Circumstances
The Fundraising Regulator defines vulnerability as 'a state in which a person is especially susceptible to harm due to their personal circumstances'. The guidance confirms that individuals under the age of 18 are always categorised as being in vulnerable circumstances. Where an adult does not have the mental capacity to properly consider their donation, they will be automatically considered to be in vulnerable circumstances. The guidance stresses that fundraisers should be alert to signs of this including difficulty in understanding, communicating or weighing decisions.
Informed Decisions
A core principle of the guidance is that all donors should be able to make informed decisions about any donations. Crucially, where a donor cannot make an informed decision due to vulnerability (for example, they lack mental capacity), the charity should not accept the donation and must return it to the donor should this become known later.
Fundraising Strategy
Charities are advised to consider vulnerable circumstances in all aspects of their fundraising strategy, in particular:
- Fundraising planning and communications: Charities should assist donors in vulnerable circumstances in making informed decisions. Fundraising communications should be clear and inclusive, with adjustments made to reasonably accommodate the needs of donors who may require assistive technology or alternative formats.
- Policies and training: Employees who may engage with donors in vulnerable circumstances should be trained in how to engage respectfully and appropriately with them. Established procedures and protocols should be embedded within fundraising policies.
- Safeguarding: Charities should assess and manage the risks associated with their fundraising activities, including considering safeguarding duties that extend to donors as well as beneficiaries.
The Fundraising Regulator's guidance on donors in vulnerable circumstances underscores the ethical and legal importance of safeguarding donors as part of a sound-proof fundraising practice.
For further guidance on any of the above topics, speak to Chris Priestley (chris.priestley@withersworldwide.com).