
Charity Complaints Policy for Donors and Beneficiaries
A charity complaints policy sets out how your charity receives, records and responds to concerns from the people it serves and the people who support it. It tells beneficiaries, donors, volunteers and the public how to raise a problem and what to expect once they do.
Holding and following a complaints policy is part of good governance. The Charity Commission's annual return asks trustees whether key policies are in place, and the Charity Governance Code (a sector standard rather than law) treats openness and accountability as core expectations.
The headline point is simple. A complaint is information, not just a problem to be defended against, and a charity that handles complaints openly is better placed to protect its beneficiaries, its donors and its reputation.
This guide explains what a complaints policy should cover, the stages of handling a complaint, and the point at which a complaint also becomes a serious incident that trustees must report to the Commission.
For the wider context, see the Charity Governance Code and the Commission's own guidance publications, which set the standard your policy should reflect.
Why a Complaints Policy Matters
Charities deal with a broad range of people. Beneficiaries may be vulnerable, donors expect their money to be used well, and the public judges a charity by how it behaves. A complaints policy gives all of these groups a clear and fair route to be heard.
A complaint can also be an early warning. A concern about a member of staff, a delayed grant or a misleading fundraising message may point to a deeper problem with safeguarding, financial controls or conduct that trustees need to know about.
Without a policy, complaints are handled inconsistently, records are patchy, and trustees lose sight of patterns. A written procedure makes responses fair, traceable and proportionate.
1. Who the Policy Should Cover
Your policy should make clear that it applies to everyone who comes into contact with the charity, not only one audience. The main groups are usually distinct in what they complain about.
- Beneficiaries and service users: concerns about the quality, fairness or safety of the support they receive, including how staff and volunteers treat them.
- Donors and supporters: concerns about fundraising practice, how donations are spent, communications, or requests for their data to be removed.
- The public and third parties: concerns about campaigning, conduct, partner organisations or the charity's behaviour in the community.
- Staff and volunteers: some concerns raised internally may sit under a separate grievance or whistleblowing route, and the policy should signpost where each type of concern belongs.
2. What a Complaint Is, and What It Is Not
The policy should define a complaint plainly, for example any expression of dissatisfaction about the charity's services, conduct or staff that calls for a response. A clear definition stops genuine concerns being dismissed as feedback.
It should also explain what falls outside the procedure, such as routine requests, enquiries, or matters covered by a separate policy. Signpost the right route so that nobody is sent in circles.
Make clear that complaints can be made in writing, by email, by phone or in person, and that the charity will help anyone who needs support to raise a concern, including beneficiaries with communication or access needs.
3. The Stages of Handling a Complaint
A complaints policy works best when it sets out a small number of clear stages with realistic time frames. A common approach uses three.
- Stage one, informal resolution: the complaint is acknowledged promptly, looked at by the relevant staff member or manager, and resolved quickly where possible.
- Stage two, formal review: if the person remains unhappy, a senior member of staff who was not involved reviews the complaint and responds in writing within a stated period.
- Stage three, trustee or independent review: the final internal stage, where a trustee or panel reviews how the complaint was handled and confirms the charity's final position.
At each stage the policy should state who is responsible, how long a response should take, and how the outcome is communicated. It should also name any external body the complainant can approach if they remain dissatisfied after the internal process ends.
4. Recording, Learning and Trustee Oversight
Every complaint should be logged in a central record showing what was raised, who handled it, the outcome and any action taken. This protects the charity and creates an evidence trail.
Trustees should receive a regular summary of complaints so they can spot patterns and act on them. Recurring complaints about the same service, person or process are a signal that something needs to change.
The policy should commit the charity to learning from complaints, not just closing them. Good handling improves services and rebuilds trust with donors and beneficiaries.
5. When a Complaint Becomes a Serious Incident
Some complaints reveal something far more serious than a service failure. A serious incident is an adverse event, whether actual or alleged, that results in or risks significant harm to beneficiaries, staff, volunteers or others, significant loss of the charity's money or assets, or significant damage to its property or reputation.
If a complaint points to abuse, harm, fraud or a major reputational risk, trustees should report the serious incident to the Charity Commission promptly and explain how they are handling it. Safeguarding incidents should also be reported to the police, obtaining a crime reference number.
Your complaints procedure and your serious incident procedure must connect, so that a frontline complaint is escalated to trustees rather than closed quietly. See the Commission's guidance on how to report a serious incident in your charity.
Quick Reference: Complaints Policy Essentials
| Element | What to include |
|---|---|
| Scope | Beneficiaries, donors, the public, and signposting for staff and volunteers |
| Definition | What counts as a complaint and what is handled elsewhere |
| How to complain | Channels available and support for those who need help to raise concerns |
| Stages | Informal resolution, formal review, and final trustee or independent review |
| Time frames | Acknowledgement and response times at each stage |
| Recording | Central log with outcomes and actions taken |
| Oversight | Regular reporting to trustees and learning from patterns |
| Escalation | Link to safeguarding and serious incident reporting where harm or loss is involved |
What Trustees Must Do
- Adopt a written complaints policy that covers beneficiaries, donors and the public.
- Publish a clear route for raising concerns and make it easy to find and use.
- Set realistic response times at each stage and stick to them.
- Record every complaint in a central log with the outcome and any action taken.
- Review complaints summaries regularly to identify patterns and risks.
- Escalate any complaint that signals significant harm, loss or reputational damage to a serious incident report.
- Report safeguarding concerns to the police and obtain a crime reference number.
Common Mistakes
- Treating complaints as attacks to be defended against rather than information to act on.
- Having no central record, so trustees never see patterns building up.
- Naming response times in the policy but failing to meet them in practice.
- Keeping the complaints procedure separate from safeguarding and serious incident reporting, so serious concerns are closed quietly.
- Offering only one way to complain, which shuts out beneficiaries with access or communication needs.
- Failing to tell the complainant what external option they have once the internal process ends.
How Policy Pros Can Help
We write bespoke charity policies that fit how your charity actually works, including a complaints policy that covers beneficiaries, donors and the public and connects cleanly to your wider governance documents. Our charity policies and procedures service gives you a clear, Commission-ready set of policies without the guesswork.
A complaints policy rarely stands alone. We can align it with your charity safeguarding policy and your serious incident reporting policy so that concerns are escalated properly rather than closed off.
For the full picture of which policies the Commission expects, start with our charity policies and annual return guide, which maps out the documents that support good governance.
Frequently Asked Questions
Does a charity legally need a complaints policy?
There is no single law that names a complaints policy, but holding and following one is part of good governance and the Charity Governance Code, which the sector treats as a standard.
The Charity Commission's annual return asks trustees whether key policies are in place, so a complaints policy is expected in practice even where it is not strictly a legal requirement.
What should a charity complaints policy include?
It should define what counts as a complaint, set out who it covers (beneficiaries, donors and the public), and explain how to raise a concern and through which channels.
It should also set clear handling stages with response times, a central record of complaints, regular reporting to trustees, and a link to serious incident reporting where significant harm or loss is involved.
When does a complaint become a serious incident a charity must report?
A complaint becomes a serious incident when it points to actual or alleged significant harm to people, significant loss of the charity's money or assets, or significant damage to its property or reputation.
In those cases trustees should report the serious incident to the Charity Commission promptly and explain how they are handling it, and safeguarding incidents should also be reported to the police with a crime reference number.
How many stages should a charity complaints process have?
A common and workable approach uses three stages: informal resolution by the relevant staff member, a formal review by a senior person who was not involved, and a final review by a trustee or panel.
Each stage should state who is responsible, the response time, and how the outcome is communicated, along with any external body the complainant can approach afterwards.
How should a charity handle complaints from donors about how money is spent?
Donor complaints about fundraising or how funds are used should follow the same recorded stages as any other complaint, with a clear written response explaining the charity's position.
If a complaint suggests funds have been lost or misused, trustees should consider whether it amounts to a serious incident and whether their financial controls need review.