What does the Charity Commission say about due diligence for grant-makers?

The Charity Commission says trustees must carry out due diligence checks on donors, beneficiaries and partners, and monitor the end use of funds. The guidance is chapter 2 of its compliance toolkit, "Charities: due diligence, monitoring and verifying the end use of charitable funds", published 3 January 2011.

What is "know your partner" in Charity Commission guidance?

"Know your partner" is Tool 8 in chapter 2 of the compliance toolkit. It lists key issues for trustees to consider about an organisation they fund or work with: its status and governance, key personnel, past relationship, financial controls, monitoring arrangements and operating risks.

What are the Charity Commission's core principles of due diligence?

Tool 16 of the toolkit lists five: identify who you are dealing with; verify identities where reasonable and risks are high; know what their business is; know what their business is with your charity; and watch out for unusual or suspicious activity, conduct or requests.

Does CC8 apply to grant-making charities?

Yes. CC8, "Internal financial controls for charities", says all charities need financial controls regardless of size. Section 6.9, "Expenditure on grants", covers grants a charity makes. It expects a policy on reviewing applications, checking the suitability of applicants, setting grant conditions and confirming that grants were used correctly. The Commission updated CC8 on 27 November 2024.

How much due diligence is enough for a small grant?

The Commission expects due diligence that is proportionate to the risk. Tool 16 says to verify identities "where reasonable, and the risks are high". A small, repeat grant to a known organisation needs lighter checks than a large first award. Record the level you chose and why.

Does the Charity Commission guidance apply in Scotland?

No. Scottish charities are regulated by OSCR, the Scottish Charity Regulator, which publishes its own guidance. Cross-border charities registered with both regulators must satisfy each. This article covers the Charity Commission for England and Wales only.

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Know your partner: what the Charity Commission expects of grant-makers

The Charity Commission expects trustees to carry out due diligence checks on donors, beneficiaries and partners, and to …

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Oct 2, 2026, 9:00:01 AM

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Know your partner: what the Charity Commission expects of grant-makers

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