SORBUS.org: From Principle to Action – A Practical Governance Framework for Charities
In November 2025, SORBUS.org published research revealing a significant governance gap across the charity sector. This article sets out a practical framework to help trustees close it.
That research, featured by Charity Times, Wealth Briefing, and FT Professional Wealth Management, analysed governance data across 151,180 charities in England and Wales. It found that only 25% had implemented all six policy areas the Charity Commission expects most charities to have, and that 28% of charities serving vulnerable groups lacked a safeguarding policy. The findings pointed to a clear problem – but stopped short of setting out how trustees should respond.
This article addresses that question. It examines the updated 2025 Charity Governance Code, considers what it offers trustees and what it does not, and proposes a framework built around three lenses: what a charity must do, what it should do, and how it can demonstrate the value it delivers. The aim is to help trustees move from governance principle to governance practice.
Background: The Governance Gap
In November 2025, SORBUS.org analysed governance data across 151,180 charities in England and Wales. The findings raised serious questions about the state of governance across the sector. Only 25% of charities reported having all six policy areas the Charity Commission for England and Wales states it expects most charities to have. More concerning, of the 43,476 charities that provide services to children, the elderly, and disabled people, 12,361 (28%) did not have a safeguarding policy. These findings are based on self-reported data from annual returns and indicate only the presence of policies. Whether those policies are effective or adhered to is unknown. The analysis points to a significant governance gap across the sector, and is bolstered by recent statutory inquiries that frequently point to ‘governance failures’ as a root cause.
The revised Charity Governance Code was released in November 2025, and for trustees, was a natural moment to reassess governance within their charities. Six months on, trustees have had time to absorb and reflect on the new code. Whether it will help address governance issues will ultimately depend not on the code itself but on its application by trustees themselves. The code operates with an ‘apply or explain’ approach, whereby trustees are encouraged to apply the code’s principles or explain why they have not. However, it offers limited guidance in how to approach this. In this aspect at least, it is consistent with the previous governance code. The purpose of this article is to propose a practical framework, to help trustees work towards a governance model that is the right fit.
The 2025 Code: What Has Changed
The 2025 Charity Governance Code represents an evolution rather than a direction change. The underlying philosophy – aspirational guidance on an apply or explain basis – remains consistent with its predecessor. The revisions are largely positive but leave the central challenge for trustees unchanged.
The most obvious change is one of consolidation and restructuring. Gone is 2020’s separate self assessment tool which asked boards to record what they were doing and where they needed to improve. Instead, the 2025 Code is a single document covering eight principles, each with a clear description of ‘how you know it’s working’, ‘behaviours’, ‘policy, processes and practice’, and ‘suggested evidence and assurance’. Gone too are the separate tracks for large and small charities, replaced by a single scalable framework with notes where expectations differ.
The structural shifts reflect changing priorities. 2020’s assumption that a charity is meeting its legal and regulatory responsibilities as a foundation has been promoted to its own ‘Foundation’ principle, necessitating the additional guidance that comes with it. ‘Decision-making, risk and control’ has split into two principles, giving each proper space. ‘Integrity’ and ‘Openness and accountability’ have merged into ‘Ethics and culture,’ engaging more proactively with transparency about failure and power dynamics. Across all principles, there is a sharper focus on behaviours – how trustees actually conduct themselves – rather than structures alone. Contemporary themes have been strengthened throughout – AI policies, social media risk, ethical investment, and people risks such as burnout, all receive mention.
The apply or explain approach reflects the steering group’s recognition that proportionality matters. What is necessary for a large national charity differs from what is right for a small local one. This is consistent with the Charity Commission’s own regulatory approach. The Commission’s chair, Julia Unwin, articulated this in her first interview in the role, describing the regulator’s responsibility as needing to be “close but not cosy” – ensuring trustees have taken the right factors into account, rather than prescribing. This emphasis on trustee judgment rather than prescribed compliance runs through both the Commission’s regulatory approach and the Governance Code’s design. It is telling that the Commission’s most substantive practical guidance comes not through the Governance Code but through its own publication, ‘The Essential Trustee’ (CC3). This document best describes the Charity Commission’s requirements and expectations of trustees and remains the most useful starting point for any trustee seeking to understand the role.
What the new Code’s revisions do not change is the fundamental challenge facing trustees. The Code identifies an aspirational, gold standard for what good governance looks like, but it provides limited practical guidance on translating this into proportionate action for any specific charity. It is right that the responsibility and decision making is ultimately down to the trustees – they are best placed to do so – however many trustee boards lack the necessary skills and expertise to do so. This is where a practical decision-making framework becomes essential.
A Framework: Three Lenses for Governance
We propose thinking about governance through three distinct lenses, each addressing the same fundamental question: what should we put in place, and why? The first lens is the legal and regulatory baseline – the essentials defined by law and regulatory guidance. The second is about fit – deciding what additional governance makes sense for your specific charity using risk-based thinking. The third is about demonstrating value – measuring and communicating the impact and efficiency of what your charity delivers. This is not a new set of concepts, but a structured approach for bringing together legal obligation, proportionate governance and a focus on outcomes and value for money.
In all its guidance, the Commission is careful when describing what a charity ‘must’ do, and what it ‘should’ do. The former is lens one, and also principle one of the Governance Code. Lens two can be articulated as what a charity ‘should’ do… based on its specific risk and opportunity profile. Most of the Governance Code, excluding principle 1, operates in this space. Lens three is a specific area that is vital to running a successful charity but that is understated in the Governance Code and in Charity Commission guidance. It is lens three where trustees can best determine the success of their charity – in the quantified benefits they deliver for their beneficiaries.
Lens One: The Legal and Regulatory Baseline
Failing to implement the Code is not a legal or regulatory breach. Failing to comply with the law is. ‘The Essential Trustee’ sets out the core duties of trustees and draws a clear distinction between what trustees ‘must’ do legally and what they are expected to consider as good practice. The musts are non-negotiable and cover a broad range of areas: compliance with the charity’s governing document, accounting and reporting obligations, safeguarding legislation, employment law, data protection under UK GDPR, and six core trustee duties including acting in the charity’s best interests and managing resources responsibly.
Some of these requirements vary depending on a charity’s structure and activities. A charitable company has different obligations than an unincorporated trust. A charity working with vulnerable adults has different safeguarding duties than a grant-giving charity, but these variations are predictable and defined. Working through them comprehensively is the first step. For many charities this is where professional advice is essential.
Lens Two: The Right Fit for Your Charity
Once the legal baseline is established, trustees face a more nuanced challenge. What additional governance structures, policies and processes are right for their charity? The analysis from the charity register demonstrated a large variation in what policies charities had implemented. Whether this is appropriate due to situational differences between charities or a result of differing approaches to governance is unknown. Regardless, a systematic approach to risk and opportunity is the most effective tool trustees have for answering this question proportionately.
The Charity Commission’s risk management guidance (CC26) provides a useful framework, but must be applied with caution. Effective risk management is not about creating a perfectly calibrated matrix or debating impact and probability rating at length. Charities can easily fall into the trap of running an overly academic exercise, focusing on scoring mechanics rather than the substance of the risks and the quality and delivery of mitigating actions. A risk register is not a governance tool. It is a record of thinking. The thinking is what matters. Identifying a charity’s top risks gives trustees a structured and logical basis for deciding which policies and processes are necessary and what level of effort is proportional for each.
Whilst the Commission’s baseline expectations – the six policy areas identified in our original analysis – represent a reasonable starting point for most charities, they are not sufficient for all. A charity whose activities generate risks not addressed by that core set needs greater controls in place. For example, a charity running activities for children or vulnerable adults faces significant safeguarding risks. Here, robust policies, clear procedures and regular training are essential. Conversely, a small grant-giving charity may face much lower safeguarding risk, but greater risk around conflicts of interest in grant decisions or the robustness of financial controls. The governance response should follow the risk, not a generic checklist.
Lens Three: Measuring Impact and Demonstrating Value
Lens three seeks to answer two fundamental governance questions at the core of the charity sector: do trustees have a clear, quantifiable understanding of the benefits their charity is delivering, and do they understand the cost of achieving those benefits? For many charities, the answer is ‘not really’. To make informed decisions about how to deploy resources to generate the greatest benefit – trustees need to know precisely where their money is going and what outcomes it is achieving.
This is especially pertinent for grant-giving charities. A charity that can clearly articulate what outcomes it is achieving, how those outcomes relate to its charitable objects, and what it costs to deliver them is far better placed to attract and retain funding, as well as build public trust, and make sound strategic decisions. Donors are increasingly focused on governance and impact when making funding decisions. Charities that cannot demonstrate impact and efficiency will increasingly find themselves at a disadvantage when competing for funding.
Common pitfalls include, counting outputs rather than measuring outcomes, and tracking spend against budgets without interrogating what is actually being delivered. This is not surprising – measuring outcomes is harder and requires capabilities that smaller charities may not yet have.
Good governance in this area starts with a clear understanding of a charity’s objects. From there, trustees should clearly define what success looks like, identify measurable indicators of that success, and establish a framework for monitoring progress. There are many approaches to measuring performance and no one size fits all. Top-down and bottom-up thinking will help trustees understand the impact they ‘are’ having – particularly when their objectives exceed their ability to ‘move the needle’. Leading and lagging metrics will help charities with long projects identify the early signs that an initiative is working, long before any benefit has been realised. Using data to inform decisions and drive improvement is its own skillset and should not be underestimated. If not in place, building this capability should be a priority considering its close proximity to the charitable purpose of each charity.
Where possible, trustees should also understand the cost of delivering different outcomes – recognising that whilst some costs can be attributed directly to specific outcomes, others such as overheads may need to be apportioned across multiple activities. For a charity providing employment support to young people, that might mean tracking not just the number of people supported but the employment outcomes achieved, how long those outcomes last, and the cost per outcome relative to other initiatives.
Value for money, in this context, means being able to demonstrate that charitable resources are being deployed effectively in pursuit of the charity’s objects. It is not an accounting exercise – it is a governance one. And it connects directly to the broader question of public trust in the charitable sector.
Conclusion: From Principle to Action
The 2025 Charity Governance Code sets out comprehensive principles and practices for good governance. Its emphasis on trustee judgment and decision-making rather than prescribed compliance is aligned with the regulator’s philosophy and a sensible stance to take. The ‘apply or explain’ approach, whilst valuable, leaves trustees to interpret and apply them within their own context. This is both its strength and its limitation.
The three lenses we have set out – legal baseline, right fit, and impact measurement – are intended to support trustees in developing proportionate governance controls. They offer trustees a structured way to answer the question the code does not resolve: what should we put in place, and why?
Start with what the law requires and understand that baseline with clarity. Then use risk-based thinking to identify what additional governance is proportionate for your specific charity. Finally, develop the capability to measure performance and make informed decisions to better serve a charity’s beneficiaries.
SORBUS’s analysis identified a gap between the policies charities reported having implemented and the policies the Charity Commission expects most charities to have. Behind this gap lies a fundamental challenge: how to translate governance principles into proportionate practices. The Code tells trustees what good governance looks like; it does not tell them how to get there. That journey – from principle to practice – is where many charities get stuck. The three lenses provide trustees with a way forward.