A public relations firm's UK charity PR checklist

What to take away

Charity Commission guidance on campaigning and political activity

The Charity Commission for England and Wales regulates charities and publishes its campaigning and political activity guidance for charities, known as CC9. A public relations firm taking a charity brief should read CC9 before drafting anything, and record which parts of it the campaign plan relies on.

The regulator's pages sit within the wider regulatory framework for charity PR and fundraising, which is set out in the Charity Commission's own guidance on GOV.UK, available at The Charity Commission - GOV.UK.

Charity law allows campaigning that supports a charity's purposes. It does not allow a charity to become a vehicle for a political party. The distinction matters for agencies because a campaign that looks like party support can put the charity's registration at risk.

Political activity is permitted where it furthers the charity's objects and is not the charity's dominant purpose. A PR team should document how the proposed activity links to the objects. That record becomes part of the audit trail and is useful if the Commission asks questions later.

A charity cannot donate to a political party or candidate. It cannot let a party use its name, logo or premises. Agency staff should treat these as hard stops, not negotiation points.

Non-party campaigners face rules under electoral law during regulated periods. The Electoral Commission publishes its own guidance, separate from the Charity Commission's. A public relations firm running a campaign in the run-up to an election should check both sets of rules.

Charities in Scotland and Northern Ireland are regulated by the Office of the Scottish Charity Regulator and the Charity Commission for Northern Ireland respectively. The campaigning principles are broadly similar, but the registration and reporting duties differ. Agencies working across the UK should not assume one rulebook fits all four nations.

The Charity Commission's guidance also covers fundraising. Public fundraising, professional fundraisers and commercial participators have specific requirements. A PR campaign that includes a fundraising appeal should involve the charity's fundraising lead from the start.

A useful internal rule: if a draft campaign could be read as telling the public how to vote, stop and take advice. The cost of pausing is small compared with the cost of a regulatory inquiry.

This is why an agency should keep a dated map of regulations on file, showing which regulator and which rule applies to each part of the work. It saves time when a client asks why a line of copy was changed.

Public procurement rules for charity and council PR work

Councils, central government departments and other public bodies buy PR and communications services under the UK's public procurement regime. The governing instruments are the Public Contracts Regulations 2015 and the Procurement Act 2023, which replaces them as its regime takes effect. The financial thresholds in those rules decide whether a contract can be awarded directly or must be advertised.

The Cabinet Office publishes the current thresholds on GOV.UK and reviews them periodically. Separate figures apply to central government bodies, to sub-central bodies such as councils, and to works contracts, which carry the highest threshold. Below the figure that applies to the buyer, a council may use its own contract standing orders, often with a requirement for three quotes. Above it, the contract must be advertised on Find a Tender and follow the full regulated procedure.

In practice, council PR procurement often splits into lots: media relations, public affairs, design, and evaluation. A public relations firm bidding for council work should check which lots are open and whether a framework is being used.

Frameworks are common in local government. A council may call off from a national or regional framework rather than run its own tender. Being on the right framework is often the difference between seeing the brief and not.

The rules also apply to grant-funded work. If a charity uses public money to commission PR, the funding agreement may impose procurement conditions even though the charity itself is not a public body. Read the grant letter before signing an agency contract.

The government's procurement policy has shifted towards wider social and economic objectives. The policy paper Procurement in the national interest - GOV.UK explains the direction of travel. Agencies should expect questions about social value, local employment and carbon reporting in tenders.

For charities that are not public bodies, procurement rules usually bite through funders rather than statute. A National Lottery or government grant may require competitive tendering for contracts above a stated value. The charity's finance team will know the exact conditions.

Below-threshold work still needs a paper trail. A council officer who awards a small contract should record why the chosen supplier was selected. Agencies should expect to provide a written quotation and a method statement even for modest jobs.

Payment terms matter too. Public bodies must pay within a set period, and late payment can be reported. A public relations firm should check the payment terms in the contract and invoice promptly against them.

Disputes about procurement are handled through the High Court under the Public Contracts Regulations 2015, not the Charity Commission. If a tender process looks irregular, the remedy is legal advice and, while the challenge period still allows, a procurement challenge rather than a regulatory complaint. Agencies should keep their own records of every submission.

For agencies reviewing their own contract positions, the UK legal boundaries guide is a useful companion to the procurement rules. It sets out where commercial freedom ends and regulation begins.

The audit trail agencies must keep when working for charities

An audit trail is the record that shows what was decided, by whom, when and on what authority. For charity PR work it is not optional. The Charity Commission expects charities to be able to account for their spending and their public statements.

Agency-side, the trail starts with the brief. Keep the original written brief, the version history of the proposal, and the client's written approval. Verbal approvals should be confirmed by email the same day.

Financial records are part of the same trail. Keep the purchase order, the signed contract, the timesheets and the invoices. If the charity is using restricted funds, the invoice should reference the fund and the project code.

Content records matter as much as money. Keep the approved copy, the final artwork, the publishing schedule and the evidence for any factual claim. If a claim is challenged, the agency should be able to show its source within minutes.

Social media is often the weakest part of the trail. Screenshots of posts, the approval chain for each post, and the date of publication should be stored. Deleted posts should be archived, not simply removed.

Data protection records are part of the audit trail. Under UK GDPR, the Information Commissioner's Office expects a lawful basis for processing personal data, a retention schedule and a record of any data sharing. A PR campaign that builds a supporter list needs all three.

Media monitoring and evaluation data should be kept too. Clippings, reach figures and sentiment analysis are evidence of delivery. If the charity reports to a funder, these records support the report.

Retention periods vary. Charity financial records are typically kept for six years. Campaign records may be kept for shorter periods, but the retention decision should be documented rather than assumed.

A simple test: if a new account manager joined tomorrow, could they reconstruct the campaign from the files? If not, the trail is incomplete. The quality checklist approach, which records the inspection rather than just the tick, is a good model for this.

Charity annual return and governance checks for PR partners

Before taking a charity client, a public relations firm should check that the charity is in good standing. The charity annual return is the main public document for this. It confirms the charity's income, spending and activities for the year.

The annual return is filed with the Charity Commission, usually within ten months of the financial year end. The rules are set out at Prepare a charity annual return - GOV.UK. An agency can view a charity's filing history on the Commission's register.

A charity that is late with its annual return may be flagged on the register. That is a warning sign for an agency considering credit terms or a long campaign. It does not automatically mean the charity is failing, but it should prompt questions.

Governance checks go beyond the return. Ask who the trustees are, when they last met, and who has authority to approve a PR budget. A campaign approved by a member of staff without trustee authority may not be binding.

The charity's governing document sets out its objects. The PR work should be traceable to those objects. If the link is unclear, the agency should ask for a written explanation before proceeding.

Conflicts of interest should be declared. If a trustee is also a director of the agency, or a supplier to it, the charity should record the conflict and manage it. Agencies should not rely on the charity to spot this.

Financial checks are proportionate to the size of the contract. For a large campaign, ask for the latest accounts and the most recent management accounts. For a small project, the annual return and the register entry may be enough.

Insurance is a governance issue too. Professional indemnity and public liability cover should be in place before work starts. The charity may ask for evidence, and the agency should keep certificates current.

For agencies weighing whether to take on a charity client at all, the commercial contract decisions article covers the terms that deserve legal review. Charity work often involves restricted funds, which affects payment and termination clauses.

A UK charity PR checklist from brief to sign-off

This checklist is written for agency teams and charity communications officers. Work through it in order. Each step produces a record that supports the next.

Common compliance failures in charity PR campaigns

The most common failure is a campaign that drifts into party politics. It usually starts with a strong line that tests well, then gets sharper with each revision. The fix is an early check against the charity's objects and a written record of the decision.

The second is a missing approval. A post goes out because someone assumed it was cleared. The fix is a named approver for each channel and a rule that nothing publishes without a recorded approval.

The third is poor procurement evidence. A council or funder asks how the supplier was chosen and the file is thin. The fix is to keep quotations, scoring notes and the award decision on file, even for small contracts.

The fourth is weak data protection. A supporter list is built without a lawful basis or a retention schedule. The fix is a short data protection statement in the brief, signed off by the charity's data lead.

The fifth is an incomplete audit trail. Invoices do not match the contract, or content versions are overwritten. The fix is version control and a simple folder structure that anyone can follow.

The sixth is a failure to report. The charity's annual return or funder report goes out without the campaign results. The fix is to build the reporting pack into the project plan from day one.

Most of these failures are cheap to prevent and expensive to fix. A public relations firm that builds the checks into its process will spend less time on remediation and more on the work itself.

Common questions