David Holdsworth closed the Association of Charitable Foundations conference on 26 November by restating the regulator’s priorities for grant‑makers: keep charitable objects central, apply the Commission’s donations guidance as standard practice, and manage AI‑related risks with the same level of governance as other decisions. The intervention comes as the Commission regulates around £102bn of charity income and £101bn of spend in 2024–25.
Demand continues to exceed supply. ACF’s Foundations in Focus 2025 reports £8.24bn in foundation grants in 2023–24, up 12% year on year, with some funders seeing application volumes rise by 100–400%. The report also notes growing use of generative AI in fundraising; Holdsworth said the Commission is seeing AI‑generated content in charity registration and grant materials.
On donations, the Commission’s guidance published on 4 March 2024 is explicit: trustees should start from a presumption of acceptance to further their purposes, but must refuse or return gifts where the law requires (for example where funds are illegal or conditions unlawful), and act only within their powers. The Commission’s press notice the same day reinforces this starting point and sets out a structured approach to assessing risk.
In practical terms, boards should maintain an up‑to‑date policy on accepting, refusing and returning donations; confirm the governing document provides a power to refuse or return; record the factors considered and the evidence; and consider ring‑fencing funds while a decision is taken. Anonymous gifts of £25,000 or more should be reported as a serious incident; where a charity lacks the power to refuse or return, Commission authority may be required.
On AI, the Commission’s April 2024 blog advises trustees to keep human oversight, avoid relying on AI‑generated outputs for critical decisions, and pay close attention to data protection, copyright and safety risks. The regulator does not plan a standalone AI code; trustees are expected to apply existing duties and the internal financial control standards set out in CC8.
Those expectations sit alongside the Commission’s sector risk assessment, which lists emerging technology and cyber harms among current threats and points to phishing and social engineering risks. Trustees are asked to reflect these issues in risk registers and keep controls proportionate to their charity’s profile.
Addressing debate about ‘democratising’ foundations, Holdsworth urged caution about governance changes that disperse decision‑making in ways that detach boards from their objects. The Commission will support considered change that remains faithful to purpose and will intervene only where legal duties and objects are overlooked.
Decision‑making standards remain unchanged. CC27 requires trustees to act within powers, be sufficiently informed, weigh relevant factors, manage conflicts and make decisions within a range a reasonable board could reach; clear minutes and a robust audit trail are expected for complex or high‑impact matters.
Holdsworth pointed to long‑run policy change as a legitimate focus for endowed funders. The government confirmed in June 2025 that the 1824 Vagrancy Act will be formally scrapped by Spring 2026; replacement measures will target organised exploitation rather than rough sleeping itself.
He also highlighted the Commission’s enabling role in major gifts. In November 2024 the British Museum received about £1bn of Chinese ceramics from the trustees of the Sir Percival David Foundation; the Commission has said its permissions team supported the transfer while preserving charitable intent and public benefit.
For foundation boards, the near‑term task is to align grants and investments tightly to objects; implement the donations guidance through policy, training and record‑keeping; adopt an AI policy with clear oversight and data safeguards; and apply CC27 standards consistently to triage and decide amid heightened demand and rising application volumes.