If your charity relies on volunteers — and most small charities in England and Wales run almost entirely on them — you may have a nagging sense that there ought to be a volunteer policy somewhere. Take a breath: no law requires one, no regulator will ask for it by name, and the absence of a document is not the same as the absence of good practice.
A charity volunteer policy is a written statement of how your charity recruits, supports, manages and thanks its volunteers — covering everything from vetting and induction to expenses, problem-solving and leaving — so that every volunteer is treated fairly and consistently, and so that the relationship stays clearly on the volunteering side of the line that separates it from employment. That last clause is the quiet heart of the subject: the policy is optional, but the single biggest legal risk — accidentally turning a volunteer into a worker or employee — is one a good policy is specifically designed to prevent.
This guide explains the honest legal position, walks through every section a good volunteer policy should contain, and links to a free template you can adapt. It sits alongside our full guide to what policies a charity needs, where the volunteer policy lands squarely in the third tier: good practice, not law, adopted because it fits what your charity does.
Is a volunteer policy legally required?
No. There is no statute that requires any charity to have a volunteer policy, and it is not among the thirteen policies the Charity Commission asks about in the charity annual return. If a funder says it is "required", that is a condition of their grant — a good reason to have one, but contractual, not legal.
Be equally clear-eyed about what is law, because volunteering is surrounded by it:
- Employment status. A volunteer has almost no employment rights — precisely because there is no contract. Gov.uk's guidance on volunteer pay and expenses warns that a volunteer who receives "any other payment, reward or benefit in kind" beyond genuine expense reimbursement, including "any promise of a contract or paid work in the future", may in reality be an employee or worker, with minimum wage and other employment rights. This is the trap the rest of this guide keeps returning to.
- National minimum wage. Section 44 of the National Minimum Wage Act 1998 exempts "voluntary workers" of charities and voluntary organisations only while they receive no money beyond expenses actually incurred or reasonably estimated, and no benefits in kind beyond reasonable subsistence or accommodation. Step outside those conditions and the exemption is gone.
- Safeguarding. The Charity Commission expects every charity to have safeguarding policies and procedures, and its safeguarding guidance applies to volunteers both as people the charity must protect and as people who must be suitably vetted for their roles.
- Health and safety. The Health and Safety Executive's simple guidance and free policy template is a sound starting point, and the duty of care it reflects extends to volunteers affected by your activities, even though they are not employees.
- Data protection. Volunteers' names, addresses, emergency contacts and DBS outcomes are personal data, so UK GDPR applies in full — including the privacy notice you owe the volunteers themselves.
So the honest position is this: the policy is voluntary, but almost everything it describes is not. That is why NCVO — the sector's authority on volunteering, whose free guidance on involving volunteers is the best single library on the subject — treats a written volunteer policy as a basic building block.
The employment status trap — and why wording matters
First, understand the one genuine legal hazard, because it shapes how several sections must be written.
A contract needs an exchange: each side gives something and is obliged to something. Volunteering, done properly, has no exchange — the volunteer gives time freely, the charity provides support and repays out-of-pocket costs, and neither side is bound. Employment tribunals look past labels at the reality: where a charity provides money or benefits beyond genuine expenses, and the volunteer is in practice obliged to turn up, the arrangement can be found to be a contract — and the "volunteer" becomes a worker or employee, with minimum wage, paid holiday and potentially unfair dismissal rights, and with arrears claims that can reach back years.
Three habits, each of them well-meaning, create most of the risk:
- Flat-rate "expenses". A round £10 per session, a weekly allowance, a top-up for loyal volunteers. These are not expenses; they are consideration — payment for turning up. They threaten both worker status and the section 44 minimum wage exemption at the same time, which is why reimbursement must always be of actual costs, against receipts.
- Fixed perks and promised rewards. Guaranteed benefits — free membership, promised paid work, automatic gifts of set value for attendance — can also amount to consideration. Genuine, discretionary thank-yous are fine; entitlements are not.
- Obligation language. "Volunteers must attend every Tuesday", "shifts are compulsory", "one month's notice required". Rotas and reliability matter, but the policy and agreement should speak of hopes and expectations — "we ask", "we hope", "usually" — never of binding obligations, and should say plainly that either side can end the arrangement at any time.
You do not need to cite case law in your policy (and this guide deliberately names none); you need to write every clause so that no exchange of obligations ever appears on paper or in practice.
What your volunteer policy should include
Here is the full anatomy of a good volunteer policy. Cover each of these in plain English — most small charities manage the lot in three or four pages.
Purpose and values
Open with why your charity involves volunteers and what it promises them: a genuine role, proper support, fair treatment and respect for their time freely given. Two or three sentences anchoring volunteering in your mission set the tone for the rest.
Recruitment and selection
Explain how volunteer roles are described and advertised, and commit to recruiting inclusively — volunteering should be open to the widest reasonable range of people, with adjustments made where you can. Selection should be proportionate: a friendly conversation for the cake stall, references and a DBS check for one-to-one work with children or adults at risk. Say explicitly that vetting is matched to the role, not applied as blanket bureaucracy.
Vetting and DBS checks
State which roles are eligible for DBS checks and at what level, and that checks are refreshed on a stated cycle. Two facts every small charity should know: standard and enhanced DBS checks are free of charge for eligible volunteers (paid applicants pay £21.50 and £49.50 respectively), and the DBS defines a volunteer for this purpose as someone spending time unpaid — except travel and approved out-of-pocket expenses — to benefit a third party who is not a close relative. People on work placements, course-required placements or trainee positions do not qualify, nor does anyone paid beyond expenses, and claiming the free check wrongly is treated seriously. Eligibility for a check at all depends on the role, which is territory your safeguarding policy should map in detail.
Induction and training
Every volunteer gets an induction: what the charity does, who their named contact is, the essentials of safeguarding, health and safety and confidentiality, and any training the role needs before they start. Keep a simple record that it happened — the first thing anyone asks for after an incident.
Roles and the volunteer agreement
Each volunteer should have a short role description and, ideally, a volunteer agreement setting out what the volunteer can expect from the charity (induction, support, expenses, insurance) and what the charity hopes for in return (reliability, following policies, upholding values). It must state on its face that it is not a contract of employment, is binding in honour only, and creates no obligation on the volunteer to attend or on the charity to provide work. This wording is doing real legal work — see the trap above — so resist the urge to make the agreement firmer; firmness is exactly what converts it into a contract. NCVO's free guidance on involving volunteers includes model wording for both documents.
Expenses
Commit to reimbursing volunteers' actual out-of-pocket costs — travel, meals while volunteering, materials bought for the role — promptly and against receipts, using a simple claim form — NCVO's free sample documents include one. State just as clearly what you will not do: flat-rate allowances, round sums or session payments, because these risk creating employment status and national minimum wage liability. Good expenses practice is also an inclusion issue: people on low incomes cannot volunteer if claiming feels awkward, so say expenses are encouraged, not merely tolerated.
Support and supervision
Every volunteer has a named person to go to, and regular, informal chances to talk about how the role is going. For most small charities "supervision" means a cup of tea and a chat once a quarter — say so, and make sure it happens.
Problem-solving procedure
Things occasionally go wrong: unreliability, friction between volunteers, behaviour that falls short. Your policy needs a problem-solving route — but deliberately not the staff disciplinary procedure. Formal disciplinary machinery — hearings, sanctions, appeals — is contractual apparatus; importing it wholesale overwhelms a voluntary relationship and helps make it look like employment. Instead: an informal conversation first, then a structured discussion with a nominated trustee or manager, then — rarely — a decision that the arrangement should end, with the volunteer told why. Keep your disciplinary policy for staff, where the ACAS Code has legal teeth; volunteers get a kinder, lighter route.
Safeguarding and boundaries
Cross-refer to your safeguarding policy rather than duplicating it, and cover the volunteer-specific ground: volunteers must know how to recognise and report a concern, who the safeguarding lead is, and where the boundaries of their role sit — no lifts, gifts or contact outside the role where the role involves children or adults at risk, unless explicitly agreed. Volunteers are also owed safeguarding: the Commission expects charities to protect everyone who comes into contact with them, volunteers included.
Health and safety
State that volunteers are covered by the charity's health and safety arrangements: risk assessments cover their activities, they receive the same safety information and equipment as anyone else doing the task, and they must report accidents and near-misses. Our health and safety policy guide covers the wider duty, including the written-policy threshold at five employees.
Insurance
Tell your insurer you involve volunteers and ask them to confirm in writing which policies cover them — public liability, and employers' liability where the insurer extends it — noting any conditions such as age limits or driving on charity business.
Data protection
Volunteers appear in your records twice over: you hold their personal data (so they need a privacy notice — the ICO's free generator has a charity variant), and many handle other people's data in their roles (so they need the same confidentiality expectations as staff). Say both, briefly, and cross-refer to your data protection policy.
Recognition
Say how the charity says thank you — a celebration event, a mention in the annual report, a card at Christmas. Keep recognition genuine and discretionary, never a fixed entitlement of set value: the point is warmth, not remuneration.
Leaving and references
Volunteers may leave whenever they wish, with no notice owed. Ask for feedback when they go — an exit conversation is free intelligence about how your charity feels from the inside. State your approach to references: many small charities will confirm role, dates and duties; if you offer more, be consistent about it.
Review
Name the policy's owner, the date adopted and the next review date. Two- to three-yearly is a sensible cycle for a volunteer policy, with an early review if the law, your activities or an incident demands it.
Download our free charity volunteer policy template (Word) — openly licensed, written for small charities in England and Wales, and yours to adapt with no sign-up.
Adopting the policy properly
A volunteer policy nobody adopted is a draft, not a policy. Tailor the template to your charity — real role types, real named contacts, your actual expenses process — then take it to the board, adopt it by a decision recorded in the minutes, and give it an owner and a review date. Involve volunteers in shaping it first if you can: they will spot the gap between what the draft says and what happens on a wet Tuesday. Trustee Meetings keeps policies, owners and review dates alongside your agendas and minutes and resurfaces each one when it falls due, so adoption and review happen by design rather than by memory — free to try, no card needed.
Common mistakes
- Paying flat-rate "expenses". The most dangerous mistake on this page. A round sum per session is payment, not reimbursement, and it puts both employment status and the minimum wage exemption at risk. Actual costs, against receipts, every time.
- Making the volunteer agreement too firm. Notice periods, compulsory shifts, "must" and "required" — every obligation added to make volunteers more reliable also makes the document more contract-like. Reliability comes from good management, not binding clauses.
- Running volunteer problems through the staff disciplinary procedure. It borrows contractual machinery for a non-contractual relationship, and it turns a solvable problem into a formal ordeal. Use a separate, lighter problem-solving route.
- Paying for volunteer DBS checks unnecessarily. Standard and enhanced checks are free for eligible volunteers; small charities quietly waste money here. Equally, do not claim the free check for anyone who fails the DBS volunteer definition.
- Forgetting volunteers in risk assessments and insurance schedules. The duty of care does not stop at the payroll, and an insurer told nothing about volunteers may take some persuading later.
- Treating the policy as a shelf document. If practice does not match the paper, the paper is evidence against you. Shorter and true beats longer and aspirational.
Reviewing your volunteer policy
Review every two to three years as a matter of course, and sooner if any of these happen: your charity starts working with children or adults at risk for the first time, you begin any payment or benefit to volunteers beyond receipted expenses (stop and take advice first), a volunteer problem exposes a gap in the problem-solving route, your insurer changes terms, or DBS eligibility rules shift. Each review is a board minute, a refreshed date on the document, and a fresh pair of eyes on the clauses that carry the legal weight — and if yours predates this decade, starting again from our free volunteer policy template may be quicker than patching it.
A volunteer policy rarely stands alone, and its neighbours matter: the safeguarding policy governs how volunteers are vetted and how everyone is kept safe, the health and safety policy carries the duty of care that covers them, the data protection policy governs the records you keep about them, and the disciplinary policy is the staff route your volunteer problem-solving procedure deliberately is not. For the full map of which policies your charity actually needs — and which it honestly does not — start with our guide to what policies a charity needs, and give every volunteer a proper welcome with the ideas in our trustee welcome pack guide.