In April 2026, the Charity Commission issued updated guidance on identifying and managing conflicts of interest in charities.
What are conflicts of interest?
Conflict of interest: a conflict of interest is any situation in which a trustee’s personal interests or loyalties could, or could be seen to, prevent them from making a decision only in the best interests of the charity.
Conflicts can arise from actual or perceived benefits, or from divided loyalties.
Conflicts may also be perceived by other charity stakeholders, even where trustees are confident they have acted in the charity’s best interests. This is why transparency and disclosure are essential to managing conflicts effectively.
Overview
The updated guidance follows Charity Commission findings showing an increase in cases involving unmanaged conflicts. Analysis of these investigations suggests that some trustees are unclear about what constitutes a conflict.
Managing conflicts is part of trustees’ legal responsibilities, and each trustee is responsible for ensuring conflicts are properly identified, recorded and kept up to date.
Failure to do so could lead to decisions being challenged, loss of funds, reputational damage, or evidence of misconduct in a Charity Commission investigation.
Conflicts of interest can take many forms, and the guidance covers a range of examples. These include loyalty conflicts, involving a person or organisation connected to a trustee, and financial conflicts, where a connected person or organisation may receive a financial benefit. The guidance also sets out a step-by-step process for managing conflicts. It reminds trustees and charities to review their governing documents for any specific rules on conflicts of interest and includes links to further guidance for charitable companies. It also highlights situations in which the Charity Commission may need to be involved. Finally, the guidance includes practical examples to help charities recognise similar issues in their own organisations.
Next Steps
We recommend that trustees and management review the updated guidance to ensure they understand how to identify conflicts of interest and manage their responsibilities effectively.
If you would like to discuss further, please get in touch with our Charities & Non-Profit team.
Please note that this content is not intended to give specific technical advice. It is designed to highlight some of the key changes rather than provide an exhaustive explanation of the topics. Professional advice should always be sought before action is either taken or refrained from as a result of information contained herein.
