WAJD Learning

Module 1 of 2 · 45 minutes

Trustees, policy and risk: what comes before the tool

By the end of this module you will be able to

  • State who is accountable for AI in fundraising
  • Say what the Charity Commission expects of trustees
  • Explain why a policy comes before a tool
  • Carry out a proportionate risk assessment
  • Avoid knowledge of AI sitting with a few people

Work through it

1 interactive for this module, built on the WAJD Teach engine. Nothing moves until you ask it to, and every one has a written version if you would rather read it.

Watch: Emma and George talk it through

2 minutes. Captions are on, and the same conversation is written out in full below. The voices are computer generated.

Emma George, I'm a trustee of a small charity. Our fundraiser wants to use AI for the Christmas appeal. Is there a rule?

George There's guidance, from the Fundraising Regulator, published on 8 December 2025. It doesn't add new rules. It shows how the Code of Fundraising Practice applies, so AI is used in a legal, open, honest and respectful way.

Emma And the Charity Commission?

George It wrote about AI in April 2024. It said it didn't anticipate producing specific new guidance. But it was clear that trustees remain responsible for decision making, and that mustn't be delegated to AI.

Emma So who's accountable if the appeal goes wrong?

George The charity, and ultimately you, the trustees. The guidance says you're responsible and accountable for your use of AI for fundraising, including that of your third-party fundraisers.

Emma Only one of us on the board understands this stuff.

George That's named in the guidance. Take all reasonable steps to avoid a situation where trustee understanding and knowledge about AI is concentrated among a minority.

Emma So what comes first?

George A policy. Before the tool. Saying when AI creates or informs content, makes decisions or carries out tasks. And reviewed regularly.

Emma Do we publish it?

George The regulator recommends you publish how you use AI in your fundraising, accessibly, on your website.

Emma And then we can start?

George After a risk assessment. The guidance says avoid using any AI tool before conducting one.

Emma We're four staff. How big does that need to be?

George Proportionate. Tidying the wording of a newsletter needs less than a tool deciding whom to ask for money.

Emma What do I ask?

George What will the tool do? What goes into it, and where does that go? What could it get wrong, and who'd be affected? Who checks the result? And what do we tell donors?

Emma And once it's written?

George Keep it with the policy. Look at both again whenever a tool, a supplier or a use changes.

The written material

Two regulators, one message

The Charity Commission wrote about AI on 2 April 2024. It said it did not anticipate producing specific new guidance and preferred trustees to apply existing guidance to new technology. It was clear on one thing: trustees remain responsible for decision making, and it is vital that this is not delegated to AI or based on AI generated content alone.

The Fundraising Regulator published guidance for using AI in fundraising on 8 December 2025. It does not add new rules. It shows how the Code of Fundraising Practice applies, so that AI is used in a legal, open, honest and respectful way.

Accountability does not move

The guidance says you are responsible and accountable for your use of AI for fundraising purposes, including that of your third-party fundraisers. Trustees are ultimately accountable.

It asks boards to take all reasonable steps to avoid a situation where trustee understanding and knowledge about AI is concentrated among a minority. One enthusiastic trustee is not oversight. The whole board needs enough understanding to weigh the opportunity against the risk.

Policy first

The guidance says to develop an AI policy before using AI tools. The policy should say when AI creates or informs content, makes decisions or carries out tasks, and it should be reviewed regularly so that it stays current.

To maintain trust, the regulator recommends publishing how you use AI in your fundraising accessibly on your website. A donor who wants to know should be able to find out without asking.

Risk assessment before any tool

The guidance is direct: avoid using any AI tool before conducting a risk assessment. Without one you may not have fully understood the effects. The assessment should be proportionate: a small charity using a tool to tidy the wording of a newsletter needs less than a large one using a tool to decide whom to ask for money.

Useful questions are the ordinary ones. What will the tool do? What information goes into it, and where does that go? What could it get wrong, and who would be affected? Who checks the result? What do we tell donors?

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