Charity Governance Code 2025 Refresh: What Changed for Trustees

The 2025 Charity Governance Code, published in November 2025, is the most significant revision since 2017. It adds a new eighth principle, splitting the former "Decision-making, risk and control" into "Decision making" and "Managing resources and risks". Equality, diversity and inclusion is elevated to a standalone principle. New expectations require boards to consider technology and AI risks, and environmental responsibility gains fresh emphasis. The refreshed Code places more weight on how boards behave, not just their structures.

What the Charity Governance Code is

The Charity Governance Code is a voluntary framework for UK charity trustees, developed by a steering group including NCVO, ACEVO, Small Charities Coalition, and the Chartered Governance Institute UK & Ireland.

It’s not a regulator’s document — but it sets the bar for what good UK charity governance looks like. Funders, regulators, and sector bodies use it as the reference. There are two versions: one for charities under £1m income, one for those above.

The 2025 Code refresh was published in November 2025 after extensive sector consultation. The previous version (2017) had stood for 8 years.

What changed in 2025

1. New eighth principle

The previous Code had 7 principles. The 2025 version has 8. The new principle structure:

  1. Organisational purpose (unchanged in essence)
  2. Leadership
  3. Integrity → merged with Openness into “Ethics and culture”
  4. Decision-making, risk and control → split into two:
    – 4. Decision making
    – 5. Managing resources and risks
  5. Board effectiveness
  6. Diversity → elevated to “Equity, diversity and inclusion” as a standalone principle
  7. Openness and accountability → merged into “Ethics and culture”

In effect: 7 → 8 principles, with significant restructuring rather than just additions.

2. EDI as standalone principle

Equity, diversity and inclusion was previously part of the Diversity principle. The 2025 Code elevates it to a fully standalone principle with expanded expectations.

What this means in practice:
– Boards expected to articulate EDI as a strategic objective, not just a compliance afterthought
– Trustee recruitment processes should evidence EDI consideration
– Beneficiary engagement should reflect EDI principles
– Reporting on EDI in the Trustees’ Annual Report becomes more expected

3. AI policy expectations

The 2025 Code explicitly recommends that charities have a policy for the use of technology and AI tools. This reflects the rapid sector adoption of AI (75% of UK charities now use AI per the Charity Digital Skills Report 2025) and the trustee-level questions that come with it.

Implication: trustees should be able to answer “what’s our AI policy?” — see our free AI policy template.

4. Environmental responsibility

A new emphasis. Boards expected to consider:
– Environmental impact in investment decisions
– Sustainable procurement
– Carbon awareness in operations
– Environmental impact in supply chain

For a £100k charity, this doesn’t mean ESG reporting frameworks — it means thinking about environmental responsibility proportionate to size.

5. Behavioural focus

Perhaps the most significant change in spirit. The 2025 Code places more weight on how boards behave, not just what structures they have.

Examples:
– Trustee culture and meeting dynamics
– Constructive challenge from individual trustees
– Active listening with beneficiaries
– Behaviours that support inclusive, ethical decision-making

This is hard to audit — but easy to recognise in practice. A board that has all the right policies but talks over each other in meetings doesn’t really meet the Code.

What your board should do

Three practical actions for any UK charity that wants to stay current:

Action 1 — Map your existing governance to the new 8 principles

If you previously did a Code self-assessment against the 2017 version, redo it against 2025. The mapping is mostly logical but the new EDI principle and new 8th split create gaps to fill.

Action 2 — Adopt an AI use policy

If you haven’t already. Use our free 2-page template. Get it approved at your next board meeting.

Action 3 — Consider environmental responsibility

For a small charity, this doesn’t need to be a strategy. It needs to be a paragraph in your Trustees’ Annual Report explaining your approach (e.g., “we consider environmental impact in supplier choices and travel decisions; we don’t have a formal carbon target, but trustees have committed to reviewing this in the next 3 years”).

From CharityIQ. CharityIQ’s compliance dashboard maps your charity’s policies and governance against the 8 Code principles. Trustees see what’s covered and what’s missing. See compliance →

Further reading

The full 2025 Code is published at charitygovernancecode.org. It’s free, well-written, and worth reading end-to-end (~30 pages).

Sector commentary that helped this post:
– Trowers & Hamlins — what’s new
– HCR Law — foundations first
– ICAEW — board behaviours focus
– Sayer Vincent — what’s new

What to do this quarter

  1. Read the 2025 Code — schedule a board session
  2. Self-assess against the new 8 principles
  3. Draft an action plan for any gaps — most charities will identify 2-4 areas to strengthen
  4. Update your Trustees’ Annual Report to reference 2025 Code adoption

Compliance, governance, AI policy — in one workflow. Start a free 14-day CharityIQ trial. Start free trial →

Frequently asked questions

No — it’s voluntary. But major UK funders increasingly use it as a reference, and the Charity Commission expects trustees to consider it as evidence of good governance.

The Code applies across the UK. Wales, Scotland, and Northern Ireland have their own equivalent documents but most reference the 2025 Code.

Most major UK charities will have addressed the changes within 12-18 months of November 2025 publication. Smaller charities may take 2-3 years.

No — both the under-£1m and above-£1m versions of the Code received the 2025 refresh. Small charities have proportionate expectations, not exemptions.

In your Trustees’ Annual Report. A standard formulation: “Our trustees have considered the Charity Governance Code 2025 and consider that we apply its principles to a degree appropriate to our size and nature.”