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What is CC29?
This document, formally known as ‘Conflicts of interest: a guide for charity trustees’, is official guidance from the Charity Commission for England and Wales (‘the Commission’). Its purpose is to help charity trustees understand their legal duties to identify, manage, and record conflicts of interest in the proper administration of their charity.
Why Is CC29 Important?
This established guidance is important for the following reasons:
- Compliance: Charity trustees have a legal duty to manage conflicts. Failure to do so can render their decision making legally invalid.
- Personal Liability: If a conflict is not managed and leads to loss, trustees may be personally liable to cover the loss from their own funds.
- Reputation: Managing conflicts helps to prevent damage to a charity’s reputation (an important asset of the charity) as well as public trust.
- Safeguard: it helps to protect charities from the misuse of funds, financial loss, and prevents the use of charity funds for private benefit.
New Updates
This latest new revised version of CC29 is not a legal rewrite but a philosophical reorientation, consciously modelled on the 2025 Fundraising Code’s shift from legalistic prescription to risk-led practicality. The most notable change is structural. Its structure is shorter, scenario-driven guidance designed for trustee usability, not regulatory comfort.
Where the old CC29 assumed charity trustees understanding, the new version explicitly acknowledges that failures often occur at the identification/recognition stage. This is a fundamental change in regulatory diagnosis. The 23% rise in private benefit cases has pushed the Commission to treat conflict-blindness as a competency risk, not a moral failing. Interestingly, the guidance now places significant weight on early identification. The classic three-step framework (identify, manage, record) remains, but its centre of gravity has moved decisively to step one. Most enforcement failures, the Commission now signals, happen before any formal process kicks in.
The tonal escalation on personal liability is another clear change. The old version of CC29 spoke in generalities; this new version warns bluntly that uninformed decisions may be invalid and that charity trustees may be personally liable for losses—without changing the underlying law. This mirrors the 2025 Fundraising Code’s technique of using sharper language to drive behavioural change.
What has changed, therefore, is not the duty, this remains the same, but rather the evidentiary baseline. Gleaming, generic conflicts of interest policies are no longer justifiable under this new version of CC29. Trustee minutes must now evidence active recognition of perceived conflicts, not just declared interests. Trustee training will now have to pivot from advisable to defensive. In short, the new CC29 increases the cost of ignorance (which is never a defence in any event) and that is precisely the point.
Take heed, the tolerance for ignorance has vanished. A policy that merely exists is no defence. A policy that trains, prompts, and evidences recognition of a conflict of interest/loyalty is your best shield and demonstration that you and your fellow board members are actively aware of your legal duties in this area.
Our experienced team are already at the forefront of advising charities of all sizes, across all sectors as to how their new conflicts of interest/loyalty policy should look, namely leaner, scenario-led, risk-assessed in real time; and structured in a bespoke way for the organisation to spot perceived conflicts very early on, before they become procedural failures. That is the style the regulator now requires of you.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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