Reporting serious incidents: Unpacking Charity Commission findings

In this blog, ACF's Policy & Communications Manager Emma Hutchins offers her view on today's report from the Charity Commission for England and Wales.

The Charity Commission for England and Wales has published the findings from its analysis of serious incident reporting by charities. According to the report, charities submitted 2,114 reports of serious incidents relating to safeguarding between 20 February and 30 September 2018, an increase of 25% on the number of reports in all of the previous year.

It found that overseas aid/famine relief charities submitted the highest proportion of reports, followed by disability charities, religious activities, education/training, and younger people charities.

The Commission believes that there is “significant and systemic underreporting” of safeguarding incidents, as only 0.9% of all registered charities have reported a safeguarding incident since 2014.

The report also announces further steps the Commission will take to improve serious incident reporting, which include developing a digital reporting tool, creating checklists to help trustees submit reports, and publishing further guidance.

What can we take from these findings?

There are few surprises in today’s findings. The increase in reporting reflects the prominence given to safeguarding practice since widespread news coverage earlier this year, and the types of charities with higher numbers of reports are typically those which interact with children and vulnerable adults.

As part of foundations’ robust due diligence checks on applicants, how charities deal with serious incidents is a key indicator of good governance and risk management. The increase in reporting is to be welcomed as a sign that incidents are being dealt with appropriately.

Today’s report is also useful in highlighting what is often a missing piece in discussions of safeguarding. The Commission’s guidance on reporting serious incidents covers many categories of incidents from financial crime to extremism. This is perhaps a reason it doesn’t always feature at the heart of safeguarding discussions, which naturally focus on preventing harm occurring in the first place.

The Commission’s conclusion that there is underreporting is understandable given the low number of incidents reported among a large number of charities. But we might dig deeper into what some of the challenges are that may prevent higher levels of reporting.

Many charities, including foundations, find that it is unclear what constitutes a serious incident, and why incidents should be reported to the Commission as well as to other relevant authorities. We can welcome the Commission’s intention to improve the process of identifying and reporting serious incidents, and hope that enabling and supporting charities to understand their responsibilities is core to this work.

What is ACF doing?

Foundations are eager to meet the needs of those they work with as well as their own regulatory responsibilities, and we are supporting them to be ambitious and effective in doing so.

We hosted a roundtable in February bringing together foundations keen to explore what more they could do in this area. Reporting and escalating concerns was a key theme; foundations want to support charities in addressing incidents without playing the role of the regulator. There are particular complexities for foundations in reporting, where they may often be removed from the incident but nonetheless aware of it.

Based on that discussion and many more, ACF developed a framework to help foundations think through their approach to safeguarding and reporting which aims to untangle some of these issues.

Coincidentally, today ACF’s Head of Policy Max Rutherford addressed these and other issues in a presentation on due diligence in grant-making, at this year’s LBG Conference at KPMG, in front of more than 100 corporate social responsibility leaders. 

He noted that: 

Due diligence in assessing and managing grants is one of the golden threads. It is an essential requirement of legal compliance, but is far more than a technocratic exercise. 

“There are the basics, such as checking an applicant’s accounts, making sure their bank statement matches the payee account, and asking questions about their governance. But, beyond these, it is about nuance, gut instinct, and experience.

“A standardised approach for all grant-makers would almost certainly fail to be sufficiently nuanced to respond to the UK’s grant-making kaleidoscope.

“That’s why, in our framework, we suggest that assessing safeguarding should be seen as a core part of due diligence more generally, and that it is proportionate, appropriate and contextualised to each and every grant awarded. 

“Any other approach will most likely fail to appreciate that due diligence in grant-making is far more of an art than a science.”

You can download the framework to which Max refers here. We want the framework to be as robust a resource for foundations as possible, so please do share your experience of using it with


Emma Hutchins
Policy & Communications Manager, ACF


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