Policies a New Charity Should Put in Place

Setting up a charity means more than registering with the Charity Commission. From the day you start, trustees are responsible for the charity's governance and for compliance with charity law, and a small set of core policies is what makes that manageable.

The Charity Commission regulates charities in England and Wales, and its annual return asks trustees questions about the charity, including whether key policies are in place. Holding and following those policies is part of good governance and the Charity Governance Code, a sector standard rather than law.

The headline point for a new charity is simple. Put the core policies in place at the start, written for your actual activities, so you are not scrambling to produce them later when a funder, the regulator or an incident demands them.

This checklist covers the policies most new charities need first: safeguarding, internal financial controls, conflicts of interest, reserves, complaints and risk. The relevant Charity Commission guidance is collected in its CC guidance publications, and the wider standard is the Charity Governance Code.

If you are still at the formation stage, read this alongside our guide to setting up a charity in the UK and our wider charity policies and annual return guide.

Why a New Charity Needs Policies From Day One

Trustees carry the legal responsibility for governance and compliance from the moment the charity exists. Policies are how that responsibility is turned into something the whole board, staff and volunteers can follow consistently.

Funders and the annual return both ask what you have in place. Putting proportionate policies in place early gives you evidence of good governance and avoids weak or missing documents becoming a regulatory concern.

The Core Policies to Put in Place

1. Safeguarding

Trustees have a duty to take reasonable steps to protect from harm everyone who comes into contact with the charity. A safeguarding policy and procedures appropriate to your activities are expected, including DBS checks where roles are eligible.

Safeguarding sits alongside serious incident reporting. A safeguarding incident should be reported to the police, obtaining a crime reference number, as well as to the Commission. See our charity safeguarding policy guide for the detail.

2. Internal financial controls

Internal financial controls (CC8) safeguard charity funds and reduce the risk of fraud and error. They cover segregation of duties, authorisation limits, dual authorisation of payments, bank reconciliations and oversight of income and expenditure.

For a new charity, even a simple, written set of controls protects both the funds and the trustees. Read more in our charity internal financial controls policy guide, and the Commission's own internal financial controls guidance.

3. Conflicts of interest

Conflicts of interest guidance (CC29) requires trustees to identify, declare and manage conflicts of interest. Where needed, a conflicted trustee is removed from the relevant decision, and what happened is recorded.

A register of interests is good practice and easy to start on day one. See our charity trustee conflicts of interest policy guide and the Commission's conflicts of interest guidance.

4. Reserves

Charity reserves guidance (CC19) asks trustees to set, document and explain a reserves policy. The trustees' annual report should state the reserves policy and the level of reserves held and why.

Agreeing your approach early, even for a small charity, makes the first annual report straightforward. Our charity reserves policy guide explains how to set one.

5. Complaints

A complaints policy gives beneficiaries, volunteers and the public a clear route to raise concerns and shows how you respond. It supports good governance and helps you spot problems before they escalate.

For new charities, a short, plain complaints procedure is enough to start. See our charity complaints policy guide.

6. Risk management

Risk management guidance (CC26) asks trustees to identify and assess the major risks the charity faces and decide how to manage them, commonly using a risk register. Larger charities must include a risk management statement in their trustees' annual report.

A simple risk register from the outset gives the board a shared view of what could go wrong. Read our charity risk management policy guide for how to build one.

Policies to Add as the Charity Grows

Beyond the core six, several policies become relevant as your activities expand. You do not always need them on day one, but it helps to know they are coming.

• Serious incident reporting, so trustees report serious incidents to the Commission promptly and explain how they are handling them (see our serious incident reporting policy).
• Trustee expenses and payments (CC11), covering reimbursement of genuine, reasonable out-of-pocket expenses (see our charity trustee expenses policy).
• Investing charity funds (CC14), where trustees should have an investment policy and may adopt responsible or ethical approaches consistent with their purposes.
• Campaigning and political activity (CC9), recognising a charity may campaign to further its purposes but must never support a political party or make political donations.
• Data protection, because any charity that processes personal data must comply with UK GDPR and the Data Protection Act 2018, regulated by the Information Commissioner's Office.

Quick Reference: Core Policies for a New Charity

Policy	Charity Commission guidance	What it does
Safeguarding	Safeguarding duty	Protects everyone who comes into contact with the charity
Internal financial controls	CC8	Safeguards funds and reduces fraud and error
Conflicts of interest	CC29	Identifies, declares and manages conflicts, with a register of interests
Reserves	CC19	Sets and explains reserves in the trustees' annual report
Complaints	Good governance	Gives a clear route to raise and resolve concerns
Risk management	CC26	Identifies and manages major risks, often via a risk register

What Trustees Must Do

• Adopt the core policies at the start, sized to your charity's real activities.
• Record conflicts of interest and keep a register of interests up to date.
• Document your reserves policy and explain it in the trustees' annual report.
• Implement internal financial controls, including segregation of duties and dual authorisation of payments.
• Maintain a risk register and review the major risks regularly.
• Report serious incidents to the Commission promptly, and safeguarding incidents to the police with a crime reference number.

Common Mistakes

• Treating policies as a one-off form-filling exercise rather than documents the board actually follows.
• Downloading generic templates that do not match the charity's activities or governing document.
• Leaving safeguarding until an incident forces the issue, rather than putting a proportionate policy in place first.
• Forgetting to record how a conflict of interest was handled, even when the decision itself was sound.
• Assuming data protection is covered by charity guidance, when UK GDPR and the Data Protection Act 2018 are regulated separately by the ICO.

How Policy Pros Can Help

We write bespoke charity policies and procedures for new charities, built around your activities and your governing document rather than a generic template. Trustees get a clear, written framework they can follow and evidence to the regulator and funders.

To go deeper on any single policy, see our guides on the charity safeguarding policy and internal financial controls, or start with the full annual return policy checklist. If you are still at the formation stage, our guide to setting up a charity in the UK covers the wider process.