Compliance · Safeguarding
Safeguarding for small charities
The Charity Commission treats failure to manage safeguarding as a regulatory concern of the highest order. The good news is that doing it properly at small-charity scale is a finite, manageable list of things.
Published by The Committee Room·Last updated 24 September 2026·6 min read
The Charity Commission’s expectations
The Commission's guidance Safeguarding and protecting people for charities and trustees (first published December 2017, last updated June 2022) says protecting people and safeguarding should be a governance priority for all charities, and that policies should be reviewed at least once a year and always after a serious incident. Trustees of any charity working with people (which is most charities) should:
- Adopt a written safeguarding policysized to the charity's activities — refresh annually, sign it as a board
- Undertake regular risk assessments of the activities, premises and people the charity engages with
- Train all staff and volunteers in recognising and reporting safeguarding concerns, proportionate to their role
- Ensure safer-recruitment procedures are in place — including DBS checks where applicable (see DBS checks for community groups)
- Appoint a designated safeguarding lead on the board — the person to whom concerns are reported
- Maintain a register of incidents and a clear route for staff, volunteers, beneficiaries and the public to raise concerns
The DBS regime in brief
England and Wales: the Disclosure and Barring Service (DBS) runs four levels — Basic, Standard, Enhanced and Enhanced with Barred List checks. Enhanced + Barred Listis the check for “regulated activity” with children or vulnerable adults (defined by the Safeguarding Vulnerable Groups Act 2006, as amended), and it is an offence to let someone you know or have reason to believe is barred engage in regulated activity. The DBS Update Service subscription is £16/year (£15 from 5 October 2026) and free for volunteers — most small charities should encourage volunteers to use it.
Scotland:Protecting Vulnerable Groups (PVG) scheme run by Disclosure Scotland; membership is a legal requirement for anyone doing a “regulated role” with children or protected adults.
Northern Ireland: AccessNI runs Standard, Enhanced, and Enhanced-with-Barred-List equivalents.
See the dedicated DBS checks guide for which roles need which check.
Reporting Serious Incidents (RSI)
Charities must report to the Charity Commission any:
- Actual or alleged adverse event causing or risking significant harm to beneficiaries, staff, volunteers, or the charity's reputation
- Significant loss of funds (the Commission's guide for losses not caused by crime: £25,000 or more, or less than that but over 20% of income; for fraud and theft there is no minimum figure)
- Criminal activity by anyone connected to the charity
- Other significant incidents, such as insolvency, forced withdrawal of banking services without an alternative, or a significant data breach
CC47 (Raising a concern with the Charity Commission) was updated in June 2025 to clarify what goes via the RSI form and what goes via whistleblowing or matters-of-material-significance channels.
The Annual Return contains a mandatory question stating there are no unreported serious incidents — knowingly or recklessly giving the Commission false or misleading information is a criminal offence (Charities Act 2011 s.60).
What a small-charity safeguarding policy contains
- Statement of purpose. Why the charity takes safeguarding seriously, who it applies to, where it applies.
- Definitions.What “safeguarding” means in your context — abuse, neglect, harm, exploitation, radicalisation.
- Roles.The designated safeguarding lead (trustee), deputy lead, every staff or volunteer's role.
- Procedures. Recognising, recording and reporting a concern. Internal escalation. External reporting (local authority, police, Charity Commission RSI).
- Safer recruitment. Application form, references, DBS check level for each role, induction.
- Training. Initial and refresher, by role.
- Review. Annual policy review by the board; named date.
NCVO, NSPCC Learning, and the Association of Chairs publish free model safeguarding policies for small charities. Use one of these and tailor — don't start from blank.
Related guides
DBS checks for community-group volunteers →
Which check level for which role; PVG (Scotland), AccessNI (NI).
Community group governance basics →
The trustee duties and decision-making framework that sits behind safeguarding.
Trustee indemnity insurance →
What TII does and doesn’t cover when a safeguarding incident leads to a claim.
Compliance hub →
All compliance guides on one page.
Sources
- Charity Commission Safeguarding and protecting people for charities and trustees (updated 1 June 2022)
- Charity Commission How to report a serious incident in your charity (updated 16 January 2026)
- Charity Commission CC47 Raising a concern with the Charity Commission (refresh June 2025)
- Charity Commission Annual Return — mandatory serious-incident question
- Safeguarding Vulnerable Groups Act 2006 (as amended by Protection of Freedoms Act 2012)
- Disclosure and Barring Service (DBS) guidance; DBS fee changes from 5 October 2026
- Protection of Vulnerable Groups (Scotland) Act 2007 — PVG scheme
- AccessNI guidance (Northern Ireland)
- NSPCC Learning model safeguarding resources for small charities