Charity Commission links emergency fundraising to disaster recovery in updates

18 October 2026

The Charity Commission’s latest guidance strengthens the framework for charities preparing for emergencies such as severe flooding, connecting contingency planning with trustee responsibilities in emergency fundraising.

The regulator revised its key guidance on emergency appeals and risk management within six months, highlighting a broader emphasis on how charities manage major operational disruptions. The updated version of "Fundraising for an emergency: guidance for charities" (CC40) was released on 26 February 2026, followed by changes to "Charities and risk management" (CC26) on 16 September 2026.

Focus is on planning, clarity and trustee responsibility

The updates to CC40 and CC26 work together to stress the importance of planning and trustee accountability. Both documents are more precise than earlier versions, with CC40 specifically designed for charities in England and Wales.

The revised CC40 guidance requires trustees to assess whether their charitable objectives allow fundraising for a particular cause before launching an emergency appeal. Once fundraising is approved, the funds must be allocated to a clearly defined purpose and used as intended, as outlined in CC40.

Trustees are instructed to evaluate the scope and complexity of the emergency alongside charity staff to determine if they have the necessary resources and expertise to respond directly. In certain cases, the guidance suggests that "supporting another organisation better positioned to deliver relief may be more effective."

The guidance underscores transparency with donors, demanding clear and descriptive fundraising appeals. Terms must be explicitly stated, including how surplus funds or shortfalls will be handled. Trustees are reminded to adhere to legal obligations and the Code of Fundraising Practice.

Contingency plans must cover hypotheticals too

Six months after the CC40 update, the Charity Commission issued the latest version of "Charities and risk management" (CC26).

CC26 addresses broader risk management, including high-impact, low-probability events that proactive risk planning should anticipate. Examples include data loss from system failures, property damage from fire or flooding, or other serious incidents that could disrupt operations.

Potential disruptions from serious incidents may involve:

- Property, equipment, or records damage

- Data loss due to system failures

- Operational downtime affecting services and beneficiaries

- Supply chain disruptions and third-party service failures

- Reputational damage and its impact on partner referrals

The risk management guidance encourages charities to develop resilience plans by considering worst-case scenarios and implementing rigorous planning strategies. The "disaster recovery planning matrix" in CC26 outlines key steps:

1. Assess necessary actions if a disaster occurs

2. Evaluate the likelihood and impact of key risks

3. Prioritize steps to restore operations post-incident

4. Resume operations safely as soon as feasible

5. Invest in testing, training, and regular plan updates

These guidance points read like CSO tasks for charities

Acknowledging challenges posed by events like flooding, the Charity Commission specifically addresses flood risk and operational continuity. CC26's risk assessment table categorizes disaster recovery and planning—with emphasis on data security, digital resilience, and asset protection—as a "medium risk" area requiring "particular attention." The updated scoring and major-event focus introduced in September 2026 demonstrate broader risks in operational resilience.

Flooding and other disruptions can occur suddenly or gradually, and charities must prepare for varying timelines, according to CC26. The guidance advises considering immediate effects, recovery through standard processes, and scenarios requiring wider assistance.

Thematic analysis in CC26 connects strategic resilience and crisis response within a more structured operational framework. The updated guidance introduces terminology for different response strategies, continuity planning, and post-disruption recovery—urging charities to assess the consequences of data loss and operational downtime.

Trustees are advised to develop contingency plans, test them against realistic scenarios, and regularly review them.

With explicit coverage of flood and fire risks, CC26's updated guidance proves especially relevant for crisis preparedness.