Charities Face Increasingly Complex Risks: What the Charity Commission’s Warning Means for Safeguarding
The Charity Commission has issued an important warning to the charity sector: the risks facing charities are becoming increasingly complex.
Published on 18 August 2026, its second annual Charity Sector Risk Assessment identifies increasing concerns around exploitation of charitable status, regulatory gaps, fraud, artificial intelligence, financial pressures, governance weaknesses, extremism and significantly, safeguarding.
For trustees and charity leaders, this should not simply be another regulatory update to read and file away.
It should prompt a conversation around the board table.
Because the risks identified by the regulator are interconnected and ultimately, many of them have the potential to cause harm to the very people charities exist to support.
Safeguarding remains a significant regulatory concern
One statistic in the Commission's announcement should particularly stand out to charity leaders:
Around a quarter of concerns raised with the Charity Commission over recent years have related to safeguarding.
That is significant. Safeguarding is not a peripheral issue for the sector. It remains a substantial part of the regulator's casework and must therefore remain firmly on the agenda for trustees and senior leaders.
The Commission particularly highlights the need for trustees to give appropriate attention to allegations involving individuals who hold positions of power or influence including spiritual influence. This is an important reminder that safeguarding risk is not simply about the characteristics or vulnerability of the person experiencing harm.
We must also consider:
What power dynamics can be at play?
Who holds it?
How is it exercised?
Who might find it difficult to challenge it?
And does the culture of the organisation make it genuinely possible for someone to raise a concern about an influential, respected or senior individual?
The regulatory gap should concern us
One of the most important elements of the Commission's assessment relates to charities delivering sensitive services to at risk groups.
Some services have another specialist regulator alongside the Charity Commission. Educational charities may, for example, fall within Ofsted's remit, while regulated care services may be overseen by the Care Quality Commission but this isn't universal.
The Commission specifically identifies areas including out-of-school settings and certain housing services, where charities may provide sensitive services to at risk people without equivalent subject-specialist regulation. The concern is that service users may have limited routes for redress where the quality of provision is inadequate.
This raises an important safeguarding question:
Who is assuring the quality and safety of provision when nobody external is routinely looking?
The absence of regulation should never be mistaken for the absence of risk. In fact, it arguably makes strong internal governance, independent scrutiny and safeguarding assurance even more important.
Trustees cannot outsource responsibility
The Charity Commission is clear that voluntary trustees carry ultimate responsibility for their charities and as charities increasingly commission services, work through partnerships, use contractors and operate across complex delivery arrangements, trustees need visibility of what is happening beyond their immediate organisation.
The Commission is specifically encouraging trustees to undertake sufficient due diligence before entering new service-delivery arrangements and to consider best practice within their particular field. From a safeguarding perspective, that due diligence should go much further than asking whether another organisation has a safeguarding policy.
Charities should understand:
how safeguarding concerns are identified and escalated;
who has safeguarding responsibility;
safer recruitment and vetting arrangements;
how allegations against staff and volunteers are managed;
how low-level concerns are identified and recorded;
training and competency requirements;
information-sharing arrangements;
how safeguarding performance is monitored;
whether subcontractors or delivery partners are involved; and
how trustees will receive assurance that agreed safeguarding standards are actually being followed.
Having a contract does not transfer safeguarding accountability.
Increasing complexity demands better governance
The regulator also reports an increase in particularly complex casework, including situations involving multiple regulators or unclear regulatory boundaries.
In the last year alone, the Charity Commission formally passed information to other agencies including police, HMRC and local authorities, 500 times, an 8% increase on the previous year.
For charities, this reinforces the importance of understanding where safeguarding sits within the wider governance structure. Safeguarding cannot operate in isolation.
There will inevitably be crossover with HR, whistleblowing, complaints, health and safety, data protection, fraud, risk management, quality assurance and regulatory reporting.
When responsibilities overlap, organisations need absolute clarity around:
Who takes ownership?
Who needs to know?
Who makes the decision to escalate?
Who reports externally?
And who checks that action has actually happened?
Ambiguity creates gaps and gaps create opportunities for concerns to be missed.
AI, fraud and emerging risks cannot be ignored
The assessment also highlights the impact of rapidly developing technology. The Commission reports that AI is already being used to facilitate fraudulent applications to register charities or obtain grants. Concerns about charitable status being abused for private benefit increased by 29% in 2025–26 to 374 cases, following a 38% increase the previous year.
For safeguarding leaders, emerging technology needs to form part of the wider risk conversation too. Artificial intelligence, online environments, identity manipulation, misinformation and increasingly sophisticated fraud all have implications for organisational safety. Safeguarding risk assessments cannot remain static while the environment around organisations changes.
Financial pressure can become a safeguarding pressure
There is another finding which shouldn't be overlooked. Two in five charities saw spending exceed their income, while one in four charities with income below £10,000 only just broke even in 2024. Financial resilience and safeguarding may appear to be separate issues. In reality, they can become closely connected.
When finances are stretched, organisations may reduce training, supervision, management capacity, quality assurance or safeguarding resources.
Vacancies may remain unfilled.
People may take on wider responsibilities.
Checks and oversight can become less frequent.
Staff and volunteers may become exhausted.
None of these automatically creates a safeguarding failure but they can create conditions in which risk becomes harder to identify and manage.
Trustees therefore need to understand not simply the financial implications of difficult decisions, but their potential safeguarding consequences too.
What should charity trustees and leaders do now?
The Charity Sector Risk Assessment is intended to help trustees consider how wider sector risks apply to their own organisations and update their risk registers accordingly. We would encourage charities to use this as an opportunity for genuine reflection.
Ask:
When did we last undertake a comprehensive safeguarding risk assessment?
Does safeguarding feature meaningfully on our organisational risk register?
What assurance does our Board actually receive?
Would someone feel safe raising a concern about our Chief Executive, founder, trustee, faith leader or another influential individual?
Where do we deliver services without significant external regulatory oversight?
How do we assure safeguarding practice within commissioned, contracted or partnership services?
Are our trustees confident in their safeguarding responsibilities?
Do we understand our emerging digital and technological risks?
Are financial pressures beginning to affect safeguarding capacity?
And perhaps most importantly:
How do we know our safeguarding arrangements are working?
Not “Do we have a safeguarding policy?”
Not “Have staff completed training?”
Not “Do we have a DSL?”
But:
What evidence tells us that people are actually safer because of the systems we have put in place?
Moving beyond compliance
The Charity Commission's latest assessment should reinforce something we speak about frequently at RLB: Effective safeguarding is about far more than compliance. It requires strong governance, professional curiosity, effective leadership, meaningful oversight and an organisational culture where concerns can be raised regardless of who they relate to.
For charities supporting children, adults at risk or people experiencing vulnerability, this is particularly important. Where external regulatory oversight is limited, organisations must be even more confident in their own systems of assurance. Trustees should not wait for an incident, complaint or regulatory intervention to discover where the weaknesses are.
Ask the difficult questions now, because strong safeguarding governance isn't about proving that policies exist. It is about being able to demonstrate that risks are understood, concerns are heard, leaders are accountable and people are protected.
How RLB Safeguarding can support charities
RLB works with charities, boards and leadership teams to strengthen safeguarding arrangements and move organisations beyond compliance.
Our support includes independent safeguarding audits and reviews, trustee and board safeguarding training, governance and assurance reviews, safeguarding risk assessments, policy development and review, DSL training and development, safeguarding supervision and strategic consultancy.
An independent safeguarding review can provide trustees with something particularly valuable: assurance about what is working, clarity about where vulnerabilities exist and a practical roadmap for improvement.
If the Charity Commission's latest risk assessment has prompted questions about your organisation's safeguarding arrangements, now is a good time to ask them.
Contact us here your free consultation now