The Charity Commission’s New Conflict of Interest Guidance: What Trustees Need to Know

I’m constantly surrounded by impassioned boards who have come to a charity because of a connection to the cause. Sometimes they are parents, former beneficiaries, professionals in the field, volunteers, founders, partners, or linked to another organisation doing similar work. In the charity sector, relationships matter - and often those relationships are exactly what make trustees so committed in the first place.

Sometimes it can feel like everyone knows everyone!

That is why the Charity Commission’s updated guidance on conflicts of interest (CC29) feels particularly timely. The law itself has not changed, but the guidance has been refreshed and clarified - and there is definitely a stronger emphasis on recognising conflicts early, managing them properly, and thinking carefully about public trust and perception.

One of the most useful things about the updated guidance is that it acknowledges the reality of modern charities. Conflicts of interest are not always dramatic or malicious. Very often they arise because good people are deeply invested in a cause.

A trustee may also volunteer for a partner organisation. A beneficiary may become a trustee. A trustee may know a potential supplier, funder, or employee. In small charities and local communities especially, overlapping relationships are incredibly common.

The updated guidance is not saying these situations cannot happen.

In fact, the Charity Commission is clear that conflicts can often be managed appropriately. What has changed is the emphasis on how proactive trustees need to be.

The guidance now places much more focus on:

• identifying conflicts early

• considering whether a conflict should be removed altogether, rather than simply managed

• recording decisions clearly

• and recognising the importance of perceived conflicts, not just actual ones

That last point is particularly important.

Sometimes a board may know a decision has been made fairly and properly - but if, from the outside, it appears blurred or too close for comfort, that can still damage trust and confidence in the charity. The updated guidance encourages trustees to think not just “Is this technically allowed?” but also “Would this look reasonable and transparent to others?”

That does not mean charities should become fearful of appointing passionate people with lived experience or sector knowledge. Quite the opposite. Some of the strongest boards include trustees with direct understanding of the issues involved. However, it does mean charities need to be honest and structured about how conflicts are handled.

For example, where a trustee has a connection to a discussion or decision, the expectation is likely to be that they declare the conflict clearly and step away from that part of the decision-making process. In some cases, particularly where the conflict is significant or ongoing, boards may need to consider whether the conflict has become too substantial to manage effectively.

What I think many charities will welcome is that the guidance is actually more practical than before. It sets out a clearer process for boards to follow rather than leaving trustees feeling they are navigating grey areas alone.

And the reality is that these conversations are becoming increasingly important.

Charities are working more collaboratively than ever. Partnerships, connected organisations, lived experience boards, founder-led charities, community networks, and blended roles all bring enormous value - but they also bring complexity. Good governance is not about removing passion or relationships from charities. It is about ensuring those relationships do not undermine trust, fairness, or decision-making.

This is also one of those areas where a bit of trustee training and open discussion can make a huge difference. Often boards are not trying to hide conflicts at all - they simply have not paused to recognise them properly or discuss how they should be managed.

And if you have ever sat in a trustee meeting thinking, “This is beginning to resemble a slightly complicated family tree,” you are certainly not alone!

The important thing is not avoiding every possible connection. It is recognising them, talking about them openly, and handling them well.

Read the full guidance here: https://www.gov.uk/government/publications/identifying-and-managing-conflicts-of-interest-in-a-charity-cc29/conflicts-of-interest-a-guide-for-charity-trustees