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.
Last updated 17 May 2026·6 min read
The Charity Commission’s expectations
The Commission's safeguarding strategy was refreshed after the Oxfam and Save the Children cases of 2017–18 and treats safeguarding failure as a regulatory concern of the highest order. 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 mandatory for “regulated activity” with children or vulnerable adults (defined by the Safeguarding Vulnerable Groups Act 2006, as amended). The DBS Update Service subscription is £16/year and free for volunteers — most small charities should encourage volunteers to use it.
Scotland:Protecting Vulnerable Groups (PVG) scheme run by Disclosure Scotland; mandatory for anyone doing “regulated work” 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 (rule of thumb: loss over 20% of income or £25,000)
- Criminal activity by anyone connected to the charity
- Failure to meet legal obligations
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 — providing a false answer is a criminal offence. Captain Tom Foundation, World Vision UK (2025) and British Museum cases illustrate that disclosure quality is now scrutinised at least as closely as the underlying incident.
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 groups →
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 strategy (refreshed post-2018)
- 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
- Protection of Vulnerable Groups (Scotland) Act 2007 — PVG scheme
- AccessNI guidance (Northern Ireland)
- NSPCC Learning model safeguarding resources for small charities