ARTICLE
29 August 2025

Charity Commission Publishes Updated Complaints Procedure And Customer Engagement Policy

WL
Withers LLP

Contributor

Trusted advisors to successful people and businesses across the globe with complex legal needs
On 10 July 2025, the Charity Commission updated its procedure for dealing with complaints and its policy on interacting with customers.
United Kingdom Corporate/Commercial Law

On 10 July 2025, the Charity Commission updated its procedure for dealing with complaints and its policy on interacting with customers.

Complaints Procedure

In the new Complaints Procedure, the definition of complaint has been narrowed to exclude any spoken or written dissatisfaction about the standard of service received during engagement with the Commission or [its] wider regulatory work that has not been resolved by staff when an issue has been highlighted (new wording in italics).

Whilst the three-month time period within which to raise a complaint remains the same, there has been a change regarding the acknowledgement period. Previously, the procedure was inconsistent about acknowledgment of claims, stating first that the Charity Commission would acknowledge a complaint within 15 calendar days, aiming to respond in full within 30 calendar days whilst subsequently, under the heading 'What you can expect from us', the Charity Commission said they would acknowledge complaints either by telephone or in writing within 14 calendar day[s]'. This has been revised in the updated procedure; the Charity Commission say they will acknowledge complaints and aim to respond within 30 working days (thereby extending the time frame for providing a response and removing the interim acknowledgment stage). A caveat is added in the new policy such that if the problem is complex and the Charity Commission needs more time, they will inform the complainant.

More generally, the Commission's complaints procedure has been simplified, for example, no detail is now provided about applying to the First-Tier Tribunal (Charity) to appeal Charity Commission decisions nor is there information about how to raise concerns about a charity (these matters are however covered in other Charity Commission guidance).

Customer Engagement Policy

The new Customer Engagement Policy replaces the former 'Unacceptable customer behaviour policy and procedure'. The section in the previous version of the policy headed 'Principles' has become 'What to expect from us' and notably, the Charity Commission has specified that they expect people to 'be truthful' when they access services, in addition to being courteous and 'engaging with the Commission in a way that does not hamper [its] ability to carry out [its] work effectively and efficiently for the benefit of all', all of which were included in the previous iteration of the policy.

There is no longer an explicit definition of what constitutes an 'unacceptable behaviour' instead there are 'types and examples' of such behaviours, and the Commission specifically states that 'this section does not cover everything but gives some examples'. The categories of what could constitute unacceptable behaviour, namely aggressive or abusive behaviour and unreasonable demands and vexatious complaints, remain the same.

Behaviour which causes staff to feel harassed is specifically addressed in the new policy, alongside behaviour which makes staff feel afraid, threatened or abused. Inappropriately using information rights as a way to re-open an issue is added as an example of an unreasonable demand.

In addition, the new policy makes the regulator's zero-tolerance stance on harassment clear by adding a separate section which references the Protection from Harassment Act 1997, and states that if harassment takes place, this behaviour will likely be reported to the police.

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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