Charity Governance: Compliance Doesn’t Pay the Bills, Fundraising Does.
The ACNC’s new Charity Resilience and Productivity Project should help a lot of charity boards manage risk. But it leaves out the thing that keeps your organisation running: fundraising (well, of course I’d say that).
Announced in August by Andrew Leigh, Assistant Minister for Productivity, Competition, Charities and Treasury, the Charity Resilience and Productivity Project is due to run from October 2026 until June 2028, with support from the ATO. Its aim is to strengthen charity governance and build capability, particularly in small and volunteer-run charities, newly registered organisations, rural and regional charities, and those working across language barriers. If you sit on one of those boards, it’s aimed at you.
Better charity governance is welcome
The project targets the problems that tend to trip boards up: muddled financial records, unmanaged conflicts of interest, internal disputes and misuse of charitable funds. It also covers new laws, cyber security, data protection, fraud and the safe use of AI, with practical sessions with regulators for the questions nobody wants to put in email.
We know these are problems impacting many charities, and in particular smaller ones. In 2024, 53% of registered charities had no paid staff, according to the ACNC’s Australian Charities Report. On those boards, a few volunteers often carry what would be several departments’ work in a larger organisation. Practical guidance and access to regulators will almost certainly help.
The project isn’t about reducing red tape. Yes, it helps charities understand their obligations and better manage risk, which is important. But for many boards, this will likely mean more work and less time for other things, like fundraising.
Where the money fits in
Read the ACNC’s announcement and you won’t find fundraising, philanthropy, donations or income anywhere in it. Though the money hasn’t been forgotten entirely.
In Leigh’s speech announcing the project, he mentioned that government had removed the $2 minimum for tax-deductible donations and is simplifying access to deductible gift recipient status. These changes will make giving, and the administration of receiving, much easier. . He also described a charity manager “…already juggling service delivery, fundraising, staffing and a board meeting on Thursday night“, which will sound familiar to most people reading this.
And he also noted that “Philanthropy can fund organisational capability as well as frontline services.“ I think he’s right, but in the project he was announcing, fundraising still sits outside the governance conversation.
The ACNC does have some guidance on fundraising, and it’s clear that a charity stays responsible for its fundraising even when an agency does it on their behalf. But that guidance is about meeting fundraising obligations, not about how boards oversee the income their charity needs to operate.
A charity can have sound policies, secure data and a well-run board, and still not have enough money to deliver services, fulfil its purpose or realise its longer-term vision.
Fundraising strategy belongs in your governing documents
The ACNC’s regulatory focus for 2026-27 is governing documents. Its point is simple: a governing document needs to “accurately reflect how the charity operates”, and an outdated one carries legal, governance and operational risk.
Now apply that test to fundraising. The ACNC’s own guidance says the decision to fundraise rests with the charity’s Responsible People, meaning your board. Yet in my experience, fundraising often doesn’t appear in the constitution, the board charter, the delegations or any committee’s terms of reference.
If fundraising pays for the charity’s core work but doesn’t feature in the documents governing how the charity operates, there’s a pretty obvious gap. And one, it seems, that the regulator is not too concerned about.
Where fundraising gets lost
Someone on your board should own Fundraising
The ACNC already places the decision to fundraise with the board, so it’s worth being clear about who carries that responsibility. That might be a board member with fundraising strategy in their remit, a seat on the fundraising committee (if you have one), and clear delegations setting out who decides what. It is also worth considering whether someone on the board has the fundraising experience to help inform those decisions. An experienced fundraiser can bring valuable knowledge to the table and help reduce some of the uncertainty that comes with fundraising decisions.
Fundraising shouldn’t be what gives when the agenda fills up
The project will probably ask more of your board, not less.
When governance work grows, something has to make room, and for boards that are without a fundraising voice at the table, fundraising can receive less and less attention..
Use this year’s review
These reforms are useful and worth doing. They aim to fix real problems. But they also represent an opportunity to look at how fundraising is governed within your charity.
The ACNC is asking charities to check that their governing documents reflect how they actually operate, so take the time to clarify who is responsible for fundraising, examine whether your board’s governance arrangement reflects best practice and give fundraising a regular spot on the board agenda. Then, decide how to protect that place when the agenda fills up.
When your board sits down to work through the changes this summer, make sure it doesn’t overlook the elephant in the room. If donations pay for the work, fundraising should be part of the conversation. If donations pay for the work, fundraising should be part of the conversation.
Because absolutely compliance matters, but it doesn’t pay the bills. Donors do.
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Make fundraising part of your governance conversation
Get in touch with Paul to discuss how your board can give fundraising the ownership, oversight and attention it deserves.