EFA is conducting the EU-wide survey to collect evidence on how the Transparency and Targeting of Political Advertising (TTPA) regulation and platforms’ interpretation of the regulation have affected the digital advertising activities of nonprofit organisations across Europe.

As such, the survey explores:

• Whether and where organisations observe changes in their digital advertising activities since the TTPA entered into force
• How platforms apply rules related to political or issue-based advertising
• And whether these developments have any implications for fundraising organisations

Responses will be analysed at national and European level, with results aggregated by country and sector. This will enable EFA to identify patterns and quantify impacts, and provide evidence for structured dialogue with EU institutions and digital platforms. The aim is to ensure that civil society fundraising is not unintentionally constrained, and future adjustments are informed by real operational data from across Europe.

The deadline to respond is the end of this month. Broad participation is critical to ensuring that any EU-level advocacy is grounded in robust, cross-country evidence so EFA encourages as many organisations as possible to take part. One response per organisation is sufficient, preferably completed by someone with hands-on knowledge of digital advertising.

Take part

More information can be found here, with the survey here.

Picture by Mariia Shalabaieva on Unsplash

The Fundraising Regulator’s new Code of Fundraising Practice came into force on 1 November 2025, updating the previous 2019 version.

The updated version contains “principles-based rules”, which it says makes it less prescriptive and more proportionate for users.

The issue of fundraiser safety has also been advanced by the UK’s Chartered Institute of Fundraising (CIOF) and the fundraising think tank Rogare. On 17 November, the organisations proposed the sector-wide adoption of a Donor Code of Conduct. More on that here. The same day, the CIOF published a page on its website detailing that many fundraisers have experienced sexual harassment in their careers, often by an external stakeholder such as a donor.

Code changes

In addition to the new rule on protection from harassment, the updated Code includes a section on fundraising platforms.

There are also new principles on transparency in ‘convenience giving’ and ‘unstaffed collections’, meaning places where someone can tap their card to donate, or are asked to add an additional amount to a retail transaction.

The Code no longer includes rules about charities making commission-based payments to fundraising staff. Instead, it says that organisations must “give appropriate consideration to… whether this fits the values [of your charity]”.

Need for interpretation

An article by Bates Wells, a law firm specialising in charity clients, says that the move to a principles-based approach is the “biggest” change in the new Code. The article says:

“Whilst there are advantages to a principles-based approach, it means that there will be a greater need for organisations to interpret the Code and assess how the rules apply to their fundraising activity. This may make it harder to know how to comply with specific Code sections.”

Lord Toby Harris, Chair of the Fundraising Regulator, says:

“The new code is clearer, easier to use and designed to reflect the realities of modern fundraising. We are grateful to the many charities and fundraisers who shaped these changes. Their input has helped us create a code that continues to protect the public, supports innovation, and reinforces trust and confidence in charitable giving.”

The regulator says that a recent survey of UK fundraisers showed that 90% are positive about the new code, with 91% feeling that it is clearer.

It has also been made somewhat shorter – the 2025 Code is 21,000 words, down from 32,000 for the 2019 version.

The Fundraising Regulator is the independent regulator of charitable fundraising in England, Wales and Northern Ireland. In Scotland, the Scottish Fundraising Adjudication Panel performs a similar role.

As fundraisers, earning and maintaining trust is essential to inspiring generosity. Without trust, donor confidence erodes, and charities struggle to fulfil their mission.

How can charities and agencies maintain public confidence while ensuring sustainable revenue streams in an era of heightened scrutiny, transparency, and evolving donor expectations? The answer lies in robust self-regulation.

To build and strengthen public trust, charities must actively listen to and respond to community feedback. Self-regulation in charity fundraising isn’t just about protecting donors – it’s about supporting and empowering them too. At the F2F Congress in Vienna, I will explore how ethical self-regulation frameworks, grounded in principles-based codes of conduct, safeguard donors and provide them with new ways to meaningfully engage with the causes they care about. This proactive approach fosters deeper connections between donors and charities while reinforcing trust and transparency in the process.

Self-regulation is more than just compliance – it’s a fundamental pillar of ethical, sustainable, effective and impactful fundraising. Here’s why.

The case for self-regulation

The fundraising sector is dynamic and diverse, spanning different markets, cultures, and regulatory environments. However, the common thread across all regions is the need for ethical fundraising that upholds public trust.

The Public Fundraising Regulatory Association New Zealand has supported and empowered members since 2006 by providing a proactive framework for self-regulation that ensures charities and fundraising agencies operate with integrity beyond just legal obligations.

By developing and adhering to self-regulatory frameworks, fundraising organisations can:

• Set clear ethical expectations to ensure fundraisers operate with integrity.
• Enhance transparency and accountability to donors, regulators, and the public.
• Proactively manage risks related to reputational damage or public scepticism.
• Strengthen industry credibility by demonstrating collective responsibility.

Principles-based codes of conduct: a flexible and ethical approach

A core component of effective self-regulation is the adoption of principles-based codes of conduct. These frameworks go beyond fixed rules to establish ethical standards that guide fundraisers in diverse and evolving circumstances.

Unlike prescriptive regulations, principles-based codes emphasise intent, impact and context, and support fundraisers to make decisions based on ethical considerations rather than just ticking compliance boxes. Key principles often include:

• Honesty – Ensuring truthful and clear communication with donors.
• Respect – Upholding donor rights and dignity at every interaction.
• Accountability – Being answerable for fundraising practices and outcomes.
• Transparency – Providing clear information on how funds are raised and used.
• Sustainability – Ensuring responsible fundraising that considers long-term impact.

Building and maintaining trust

Trust is the foundation of all successful fundraising. Without it, donor engagement diminishes, and the communities and beneficiaries we serve are directly impacted. Self-regulation fosters trust by setting high ethical standards and demonstrating a commitment to responsible and transparent fundraising.

Strategies for maintaining trust include:

• Open and honest communication – Donors should know how their contributions make an impact.
• Clear complaints and compliance mechanisms – Avenues for addressing concerns must be accessible and effective.
• Third-party accreditation and oversight – Independent reviews help reinforce credibility.
• Consistent ethical behaviour across all channels – Whether in face-to-face fundraising, telemarketing, or digital marketing, integrity must remain at the core.

Future-proofing fundraising: the role of self-regulation in long-term success

As fundraising landscapes evolve ­– whether due to technological advancements, economic shifts, or regulatory changes – self-regulation provides charities and agencies with the flexibility to adapt without compromising ethical integrity. By embedding these frameworks within their operations, organisations can not only navigate challenges with confidence and ethical clarity, but innovate responsibly while maintaining donor trust, and establish long-term sustainability through consistent ethical practices.

About the International F2F Fundraising Congress

Where: Vienna

When: 28-30 April 2025

EFA discount: Thanks to the support of additional social funding for the event, the F2F Congress host Fundraising Verband Austria is pleased to be able to offer a 20% discount on tickets to EFA members and Fundraising Europe readers, accessible with the code EFA20 when booking here. 

More information: www.f2f-fundraising.com

Sessions at the F2F Congress on self-regulation include Angela Norton’s Building Trust & Sustainability: How Self-Regulation Strengthens & Future-Proofs Your Charity’s Fundraising, and Helping You Fundraise Sustainably, Ethically, and Effectively in Any Circumstance, co-presented with Matt Radford, which will delve into practical applications of the principles explored in the article, offering insights into how charities and agencies can embed ethical practices into their daily fundraising operations. View the full programme here, and read more in this month’s story.

About Angela Norton

With over a decade in charity fundraising, Angela Norton works to drive transformative self-regulation that is focused on supporter experience, ethics, transparency, and accountability. As national manager for the Public Fundraising Regulatory Association (PFRA), she collaborates with members to strengthen a self-regulatory framework that builds public trust and empowers support for valued causes.

Main picture by Vicki Hamilton on Pixabay

The paper is co-signed by the EU AML NPO Coalition, which comprises Philea (Philanthropy Europe Association), Civil Society Europe, the European Center for Not-for-Profit Law, and Human Security Collective, as well as EFA.

With the EU’s Anti-Money Laundering and Countering the Financing of Terrorism Regulation currently under negotiation, the EU AML NPO Coalition members have submitted the paper because they consider the risk of abuse to be low for public benefit purposes crowdfunding platforms and crowdfunding service providers established by nonprofit legal entities. This assessment is based on available official reports and other evidence.

Instead of including public benefit crowdfunding platforms and service providers under the category of obliged entities, they argue that whether or not to exempt providers of these crowdfunding platforms could be left to the discretion of Member States. This, the paper states, would be appropriate “because of the proven low risk posed by the nature and, where appropriate, the scale of operations of such entities.”

The coalition sets out four key arguments in detail for excluding public benefit crowdfunding platforms and providers, which are:

1. The evidence of the (low) risk of misuse for terrorism-financing for charity / public benefit-based crowdfunding;
2. The lack of a definition of crowdfunding service and crowdfunding service provider(s) in the Commission proposal;
3. The need to consider already existing regulation and take fundamental rights into account; and
4. The impact of considering public benefit crowdfunding service providers as obliged entities.

Moreover, they add:

“We consider that the exclusion of these entities from the list of obliged entities – and, therefore from the additional burdensome requirements required for obliged entities – would reflect the different role of public benefit purpose crowdfunding established by NPOs as legal entities, also achieving the positive effect of helping NPOs establish or increase donations.”

The paper will also be sent to other EU institutions involved in the negotiations in the coming days.

Picture by Florian Pircher from Pixabay

ECNL, with the support of fundraising experts, has created the document to enable the legal and policy environment for private giving to be mapped at national level. The aim is to identify good practices as well as gaps that need improvement and reform.

Mapping Fundraising for CSOs – A Monitoring Guide to the Regulatory Environment for Philanthropy is based on the areas of the Fundraising Principles that provide a global overview of current trends in fundraising regulation and self-regulation. It also builds upon the lessons learned from ECNL’s work in mapping out the environment for financial sustainability and philanthropy in several countries.

Set out in columns, the Guide takes users through different fundraising methods with questions to ask and consider to enable the regulatory environment to be mapped. These are grouped under legislation, self/co-regulation, and implementation/practice.

The document can be freely viewed and downloaded from the ECNL site, and will be reviewed and updated when necessary to ensure it reflects new issues and emerging needs.

Eszter Hartay, senior legal manager at ECNL commented:

“Private giving is vital for civil society organisations to help resolve global challenges and to support people in need but it is affected by a complex matrix of legislation, self- and co-regulation and practices that are fast-evolving and often hard to locate. The guide helps you ask the right questions to map the legal and policy environment for philanthropy in your country.”

She added:

“The monitoring guide does not aim to imply that all the issues that are mentioned in it need to be regulated. For civil society to carry out their important work, basic legal guarantees should be provided, but at the same time it is crucial to avoid overregulation limiting fundraising efforts.”

CNIL has warned against using Google Analytics because all data hosted through the tool is held in the US. Under GDPR, personal data transfer outside of the EU is restricted to ensure transfers only occur if the same level of protection can be guaranteed as within the EU. CNIL considers the measures Google has put in place to be insufficient.

To help nonprofits move from Google Analytics to other, GDPR compliant tools, France générosités undertook a review of those on offer. This saw a working group of 30 web marketing experts from its member base compile a comparative matrix of 15 compliant alternatives approved by CNIL, with the benchmark of different solutions now available to the France générosités network.

To help nonprofits outside of its network, France générosités has also made public its key takeaways and recommendations from the study.

“With the 2021 Generosity Barometer showing that online donations represented a quarter of the overall total collected in 2021 from one-off donations, it is an area well worth investing in,” commented Corentin Hue, France générosités digital project manager.

As well as ensuring a fine is avoided, France générosités notes another benefit of using compliant analysis tools – more data. This is thanks to the more precise tracking that is possible through a hybrid mode with cookies, which many of the newer solutions offer. Previously some of its members had observed between 50% and 80% data loss on their Cookies Management Platform due to GDPR compliance on cookies use.

When looking for a new tool, the working group’s review recommends:

– Testing a number of tools during the decision-making process, alongside Google Analytics, to enable a comparison of the resulting data.

– Involving all relevant departments in the process and considering the organisation’s likely future requirements

– Undertaking all due diligence to ensure the documentation provided and the support available for the tool meet requirements, and documenting the entire process – also essential for GDPR compliancy.

There is also a summary of criteria for nonprofits to consider when creating their own list of alternatives to Google Analytics, from compatibility with data visualisation tools, to whether they plan to continue using classic quantitative data or to move towards heat map journeys or solutions for example, and what APIs and data feedback campaign managers require from the different channels.

Providing additional support, CNIL has produced a Q&A on the topic, which explains in more depth why Google Analytics can’t be used under GDPR.

More on this topic: Is Google Analytics on its way out?

Picture by Pexels on Pixabay

Fundraising Principles is a global overview of trends in fundraising regulation and self-regulation, offering principles and recommendations in seven key areas based on international and regional standards and country practices.

Developed by the ECNL and the International Center for Not-for-Profit Law (ICNL) with the support of a group of fundraising experts, they are designed to serve as a reference point to promote and facilitate further dialogue between civil society organisations and policy makers.

ECNL suggests using the principles and recommendations for a variety of purposes, including assessing existing or proposed legislation or regulation impacting fundraising, facilitating discussions about how existing laws, regulations, and practices could be improved, and supporting advocacy efforts to create an enabling environment for private giving within and across countries.

The 7 areas:

Fundamental guarantees, with principles and recommendations including states guaranteeing the right for civil society organisations to fundraise for any legitimate non-profit purposes, and to be informed and actively involved in the development, implementation and assessment of laws and policies affecting fundraising.

Fundraising methods, with principles and recommendations including for states to allow and encourage the use of the broadest possible range of fundraising methods, and ensure that any regulations impacting fundraising methods are clear, necessary and proportionate to the interests protected.

Data protection & right to privacy, with principles and recommendations such as ensuring that reporting and disclosure requirements do not violate the right to privacy of civil society organisations (CSOs), their donors and beneficiaries, that the scope of personal data collected and the time it is stored is limited and proportionate to the specific fundraising purpose, and that donors and beneficiaries have the right to access information about their data and ask for removal at any time.

Cross-border fundraising, with principles and recommendations including that states do not impose restrictions or intrusive procedures on the receipt and use of international funding and on the outflow of domestic funding to CSOs abroad, and that CSOs receiving international funding are not stigmatised.

Taxation, with principles and recommendations for states including providing preferential tax treatment and tax exemptions to a broad range of CSOs, providing tax benefits in an impartial and transparent manner, and encouraging philanthropy by providing meaningful tax benefits for donors.

Transparency, accountability and oversight, recommending that any reporting and disclosure requirements are proportionate to the legitimate aim, follow a risk-based approach and are not used to stigmatise CSOs based on their donors, and that any oversight is fair, objective and non-discriminatory and does not jeopardise the independence of CSOs.

Registration, licensing and permission, with principles and recommendations including that states ensure that any authorisation, licensing, or notification requirements for fundraising activities are necessary and are the least intrusive means to achieve the desired objective, and that any authorisation, licensing, or notification requirements for fundraising activities are proportionate.

Commenting on the launch, co-author Eszter Hartay, from ECNL, said:

“Amid the ongoing worldwide COVID-19 pandemic, the need for philanthropic support and solidarity is bigger than ever. The current situation has also highlighted the importance of supporting philanthropy and the flow of donations. We hope that the Fundraising Principles will empower CSOs and fundraisers to advocate for a more enabling environment for philanthropy across borders.”

Fundraising Principles can be accessed and downloaded from ECNL’s site.

Pia Tornikoski, secretary general of the Finnish Fundraising Association VaLa, and member of the working group for fundraising legislation reform that proposed and worked on the Act, commented:

“Particularly during the current situation with COVID-19 when charities are losing income because of cancelled events, a great advantage of the new Act is the ability it grants charities to react quickly with appeals. Hopefully people are willing to donate and charities will at least get some compensation for their loss.”

Under the previous laws, charities applying for a permit to collect funds had to send their one to two year fundraising plans to the police for approval, setting out how they planned to appeal for funds during this time and the channels they would use. Permits granted under the old Fundraising Act were also all fixed-term. As of 1 March, this is no longer the case, with permits valid indefinitely, and the new law also making it easier to organise smaller appeals.

Under the new Act, fundraising requires either a licence granted by the National Police Board for an indefinite period, or the submission of a notification to a police department in the case of small-scale fundraising. For a fundraising licence to be granted, the organiser must be a not-for-profit entity and the fundraising for charitable purposes only. The fundraising organiser also has to be a corporation or foundation registered in Finland.

Small-scale fundraisers can organise fundraising up to twice per calendar year and the maximum amount that can be raised each time is set at EUR 10,000. This is restricted to associations, foundations or religious communities registered in Finland and political parties entered in the party register, as well as groups of at least three adults permanently resident in Finland.

The coronavirus has hit the world by storm, affecting virtually every aspect of our daily lives as well as our businesses. Across continents, people are either working from home or not working at all. Apart from a few types of business that cater to the specific needs created by this crisis, most organisations are ailing and forced to swiftly adjust and adapt their day-to-day operations to the new circumstances. Unfortunately, charities and fundraisers are no exception.

On the one hand, COVID-19 measures imposed by governments affect the operational side of things, on the other hand donations and other types of revenue are drying up. For example, rules regarding social distancing mean that organisations such as homeless shelters or those assisting disabled people have to drastically change their operations. At the same time, many campaigns and other fundraising activities have screeched to a halt while donors and potential donors may want to hold on to their money for the time-being, due to the economic insecurities caused by the crisis.

Governmental institutions are experiencing a similar shock to their systems. At EU level, the European Commission, as well as the European Parliament, have considerably slimmed down their legislative agendas. Meetings and these are largely happening via video conferencing with any votes taking place electronically.

What is remarkable however, is that one of the very few surviving items on  the European Commission’s legislative calendar is the Action Plan on Anti-Money Laundering (and terrorism financing). As outlined in the March edition of Fundraising Europe, this proposal envisages far-reaching harmonising measures, as well as transnational coordination, that can pose significant regulatory and administrative burden on the sector.

Obviously, the fight against money laundering practices as well as countering terrorism financing are very important. However, now more than ever it is crucial to sensitise EU decision-makers to the vulnerable position of the fundraising community. Now is not the time to impose measures, potentially crippling an already struggling sector. Therefore, a balanced and risk-based approach is of the essence.

The European Fundraising Association calls on the European Commission to enter into a constructive dialogue with the NGO sector when discussing Anti Money Laundering and anti-terrorism financing , in order to understand the significant impact of the COVID-19 crisis and to work towards a solution that is both effective and feasible.

 Patrick Gibbels, director, Gibbels Public Affairs 

On 12 February 2020, by means of a roadmap, the European Commission announced its plans for updating the existing EU regulatory framework to combat money laundering and the financing of terrorism. This may well lead to tightened legislation and more administrative burden for charities when transacting large sums of money across international borders.

Last July, the European Commission adopted a package (a collection of regulatory initiatives), which highlighted a number of shortcomings in the implementation of the current framework. Moreover, recent money laundering scandals have put pressure on the EU to re-evaluate the current system and to assess whether a more comprehensive approach at EU level is needed.

Currently, the rules are based on the 5^th Anti Money Laundering Directive and last year’s July AML Package. The Commission has thus far taken a minimum harmonisation approach, which means that the legislation is unified only at a basic or ‘minimum’ level, leaving a lot of room for Member States to adapt new legislation to their domestic systems. However, the Commission now argues that this has resulted in fragmentation across the 27 national frameworks, creating loopholes for criminals to engage in cross-border money laundering.

Because of the international nature of the scandals, the Commission does not believe that increased action by the Member States will be sufficient to tackle this problem and is not convinced that even full implementation of these latest provisions would remedy the current weaknesses. The EU is therefore leaning towards implementing a more harmonised approach. It is also considering setting up a transnational EU body to coordinate actions for Financial Intelligence Units.

For fundraisers and charities, this may result in even stricter regimes and could mean additional regulatory and administrative burdens. Whilst we do not yet know what the upcoming initiative entails exactly, it is safe to assume that such an approach might lead to additional layers of registration, stricter record-keeping, and heavier reporting requirements. In order to come to a balanced approach, the Commission has opened a public consultation on the matter, where feedback can be given on the Commission’s plans until 11 March 2020.

The European Commission’s Directorate General for Financial Stability, Financial Services and Capital Markets Union (FISMA) has confirmed that the next step after the consultation will be the launch of a policy communication at the end of March. This Action Plan will in turn serve as the basis for further extensive consultations of stakeholders. Member States will debate it in the context of the Expert Group on Money Laundering and Terrorist Financing and the FIU Platform. The Commission services will also hold meetings with stakeholders to get their opinions. This can be an opportunity for the charity sector to engage but requires you to proactively approach the European Commission. Future legislation is expected to be introduced at the beginning of next year.  

EFA will, together with its partners EFC, Dafne and Civil Society Europe, actively plead for a balanced initiative, with a risk-based approach for the NGO sector.

 Patrick Gibbels, director, Gibbels Public Affairs