Most trustees meet the complaints question in one of two ways: someone has actually complained and nobody is quite sure what happens next, or the Charity Commission's annual return has asked whether the charity has a complaints handling policy and the honest answer is "not really". Neither situation means you are in trouble. It means you are at the point where most small charities write this policy — and it is one of the quicker policies to get right.
A charity complaints policy is the document that tells beneficiaries, donors, volunteers and members of the public how to raise a concern about your charity, how you will look into it, how quickly they can expect a response, and where they can take the matter if they remain unhappy. For most charities in England and Wales there is no statute that requires one — but the Commission asks about it every year, the Code of Fundraising Practice requires a complaints procedure if you fundraise from the public, and a charity that handles complaints badly loses trust far faster than one that occasionally gets things wrong.
The good news: a small charity's complaints policy can be two or three pages. What matters is that it is public, honest about timescales, and actually followed. This guide walks through the legal position, every section your policy should contain, and the escalation routes you should describe truthfully — including what the Charity Commission will and won't do.
Is a complaints policy legally required for charities?
For an ordinary charity, no Act of Parliament requires a complaints policy. But three regulatory hooks mean almost every charity should have one, and some must.
First, the Charity Commission's annual return asks charities completing it whether they have a complaints handling policy — it is one of thirteen policies the 2023–26 return names, alongside safeguarding, internal financial controls, reserves and others. Answering "no" is not an offence, but it is a signal to your regulator, and the question exists because the Commission expects complaints to be handled properly. The pillar guide to what policies your charity needs covers the full list.
Second, if your charity fundraises from the public, a complaints procedure is required for compliance with the Code of Fundraising Practice — the current version took effect on 1 November 2025. Standard 2.3.1 requires "a clear and publicly available fundraising complaints procedure which fundraisers can explain to existing or potential donors". Standard 2.3.2 requires you to investigate complaints thoroughly and fairly, respond appropriately, avoid unnecessary delays, and "regularly review complaints and use any relevant learning to make improvements to future fundraising". Trustees carry responsibility for this: fundraising is a trustee duty under the Commission's guidance CC20.
Third, if your charity is large enough to be subject to statutory audit, section 13 of the Charities (Protection and Social Investment) Act 2016 (which inserts section 162A into the Charities Act 2011) requires the trustees' annual report to include statements about your fundraising — including "the number of complaints received by the charity or a person acting on its behalf" about fundraising activity. You cannot make that statement accurately without a complaints log.
One further point trustees sometimes miss: a complaint is occasionally the first sign of something serious — abuse, significant fraud, harm to beneficiaries. Where that is the case, the complaint may also be a serious incident that trustees should report to the Charity Commission. Your policy should say who makes that judgement.
What your charity complaints policy must include
Here is the anatomy of a complaints policy that works for a small charity — each section named, with what good looks like.
Purpose and scope: who can complain
State plainly that anyone affected by your charity's work can complain: beneficiaries and service users, donors, volunteers, partner organisations and members of the public. Define a complaint simply — an expression of dissatisfaction about your charity's actions, services or people that needs a response. Then draw the one boundary that matters: employees raising concerns about their own employment use the grievance procedure instead, so cross-refer to your grievance policy rather than duplicating it. Volunteers usually sit inside the complaints route unless you have a separate volunteer problem-solving procedure.
How to complain: channels and accessibility
Offer more than one channel — email, post, phone, and in person — and name the role (not the person) complaints go to, with an alternative route if the complaint is about that role-holder. In the Commission's thematic review Every complaint matters, most complaints came from people close to the charity — supporters, volunteers, beneficiaries — which is exactly why the route must feel safe and easy, not adversarial. Say that you will accept complaints made on someone's behalf, and that you will make reasonable adjustments: a beneficiary who cannot write a formal letter still gets their complaint heard.
Stages: informal resolution, formal investigation, appeal
Three stages are enough for almost any small charity. Stage one is informal: the person closest to the issue tries to put it right quickly, often with a conversation and an apology. Stage two is formal: the complaint is put in writing (or written down for the complainant), an appropriate person — usually the charity manager or a trustee not involved in the events — investigates and gives a written response. Stage three is an appeal to someone more senior and previously uninvolved, typically the chair or a small panel of trustees, whose decision is final within the charity. Resist adding more stages; a five-stage procedure borrowed from an NHS trust will collapse the first time a volunteer-run charity tries to follow it.
Timescales a small charity can actually keep
Set deadlines you can meet with the people you actually have. A realistic pattern: acknowledge within 5 working days, respond in full at stage two within 20 working days, and decide appeals within a further 20 working days. Build in an honest escape valve: if an investigation genuinely needs longer, the complainant is told why and given a new date. Missed deadlines do more damage than modest ones — the Commission's review found that ineffective procedures and failures to listen, respond or explain increase suspicion and frustration, and make escalation to the regulator more likely.
Recording and the complaints log
Every formal complaint goes in a log: date received, complainant (or "anonymous"), summary, whether it relates to fundraising, actions taken, outcome, and date closed. This single document answers the annual return question, supplies the complaint numbers audited charities must report under section 13 of the 2016 Act, and gives trustees their evidence base. Keep it proportionate — a spreadsheet is fine.
The learning loop: reporting trends to trustees
The point of a complaints log is not filing; it is learning. Commit in the policy to a short trustee report — at least annually, quarterly if you handle many complaints — covering numbers, themes, and changes made as a result. This is precisely what fundraising standard 2.3.2 requires for fundraising complaints, and it is good governance for everything else. Many boards track the resulting actions in a trustee action log so lessons do not evaporate between meetings.
Fundraising complaints and the Fundraising Regulator
If you fundraise from the public, give fundraising complaints their own short section. Say that your fundraising complaints procedure is public, that fundraisers (including volunteers and any agency working for you) can explain it to donors, and that if a complainant is not satisfied with your final response they can go to the Fundraising Regulator, which investigates complaints against the Code of Fundraising Practice. The regulator expects the charity to have had first chance to resolve the matter, so a working internal procedure is your best protection against an avoidable investigation.
Unreasonable or persistent complainants, handled fairly
Occasionally a complainant will not accept any answer, or behaves abusively towards staff and volunteers. Your policy should say — calmly and fairly — that where a complaint has completed all stages, the charity may decline to reopen it without new evidence, and that abusive or discriminatory behaviour towards staff may lead to contact being restricted to a single named channel. The safeguards matter: any restriction is decided by the chair or trustees (not the person complained about), explained in writing, and time-limited with a review date. Never use this section to shut down a merely persistent complainant who has a point.
Confidentiality and data protection
Complaints involve personal data, often sensitive. Commit to handling complaint records in line with your data protection policy: information shared only with those who need it to investigate, records kept securely for a stated retention period (three years from closure is a common, defensible choice), and complainants told that raising a concern will never count against them as a beneficiary or supporter.
Escalation, serious incidents and review
Finish with three housekeeping commitments. First, escalation described honestly (more on this below). Second, a line stating that where a complaint reveals possible significant harm, financial crime or another serious incident, the trustees will consider their duty to report a serious incident to the Charity Commission — and safeguarding concerns follow the safeguarding policy immediately, without waiting for complaint stages. Third, a named owner and a review date.
Download our free charity complaints policy template (Word) — openly licensed, written for small charities in England and Wales, and yours to adapt with no sign-up.
Where complaints can go beyond your charity — the honest version
Many charity complaints policies end with "if you are still unhappy, contact the Charity Commission". That line is misleading, and your policy should not use it.
The Charity Commission is not a general complaints ombudsman. Government guidance on complaining about a charity is explicit: complain to the charity directly first, and the Commission gets involved only where there is a serious regulatory concern — a charity not doing what it claims, losing significant funds, harming people, being used for private gain, or involved in illegal activity. It will not adjudicate a dispute about the tone of a letter or the quality of a service. Telling complainants otherwise sets them up for a dead end and makes your charity look evasive when the Commission declines to act.
The honest escalation map for your policy is:
- Fundraising complaints — the Fundraising Regulator, after your own procedure has finished.
- Serious regulatory concerns (significant harm, major financial loss, criminality) — the Charity Commission, and in these cases the trustees may themselves have a duty to file a serious incident report rather than wait to be reported.
- Everything else — your appeal stage is genuinely the final step, and it is better to say so plainly than to invent an external referee who does not exist.
If your charity works in a regulated field — a care service registered with CQC, a school, an advice service — name the relevant sector regulator or ombudsman too. That is a genuine route, and complainants respect a policy that maps it accurately.
Adopting your complaints policy properly
A complaints policy takes effect when the board adopts it, not when the file is saved. Tailor the template to your reality first: real role names, channels you actually monitor, timescales your team can keep. Then put it to a trustees' meeting, record the adoption decision in the minutes, and give the policy an owner and a review date. Publish it — on your website if you have one, and available on request if you don't; a fundraising complaints procedure must be publicly available to comply with the code. Trustee Meetings stores each policy alongside your agendas and minutes, with its owner and review date, and resurfaces it when the review falls due — free to try, no card needed.
Finally, brief the people who will meet complaints first: the volunteer on the phone, the fundraiser with the collection tin. A policy nobody at the front line has heard of protects no one.
Common mistakes with charity complaints policies
These are the failures that actually happen, not hypotheticals.
- One channel, and it's the wrong person. If the only route is "email the manager" and the complaint is about the manager, your procedure fails at step one. Always provide an alternative route to the chair.
- Big-charity timescales. Promising a 10-working-day full response with no paid staff guarantees broken promises. Set dates you can keep; complainants forgive slower answers, not silence.
- Defensive first responses. The Commission's review found that failing to listen, respond or explain increases suspicion and frustration — and makes escalation to the regulator more likely. An early, genuine "thank you for telling us, here's what happens next" defuses most of them.
- No log. Without a complaints log you cannot answer the annual return question, cannot produce the section 13 complaint numbers if audited, and cannot show trustees any trends.
- Routing staff grievances through the complaints procedure. Employment concerns carry their own legal framework; mixing the two muddles both. Cross-refer to the grievance policy and keep the boundary clean.
- Promising the Charity Commission as an appeal body. It isn't one. Describe escalation honestly, as above.
- A policy that exists but isn't findable. For fundraising charities this is a straightforward code compliance gap; for everyone else it quietly tells complainants you'd rather not hear from them.
How often to review a complaints policy
Review every two to three years as a matter of routine — a quick agenda item, not a rewrite. Bring the review forward when something changes: your first serious complaint exposes a gap in the procedure; you start fundraising from the public (the code's requirements then apply, including public availability); the Fundraising Regulator or Charity Commission contacts you about a concern; the Code of Fundraising Practice is revised, as it was from 1 November 2025; or the annual return questions change. Each review should look at the complaints log as well as the policy text: if complaints keep arising in the same place, the fix is usually operational, not editorial. A board that tracks its policies with owners and review dates — the approach Trustee Meetings is built around — treats this as ten minutes a year, not an annual scramble. When you review, check the free template for updates too; it is maintained against the current code and annual return.
For the wider picture, the pillar guide linked at the start of this article maps every policy your charity is likely to need, and the procedures that share borders with complaints — grievance for concerns raised by employees, safeguarding for complaints that disclose harm, and data protection for handling complaint records lawfully — each have their own guide linked in the relevant section above. If you are tightening up board rhythm more generally, our guide to how often trustees should meet is a practical next read.