Open Letter to Helen Stephenson CBE, CEO of the Charity Commission for England and Wales

A message from the CEO

Dear Fellow #WorldChangers:

How do we solve complex problems? Whatever our approach, we can’t get far without good data. Reliable, complete, up-to-date information is a central part of tackling today’s most complex challenges – from poverty and inequality to discrimination and disadvantage. That’s part of our core mission: tackling inequality through quality education. Better data means more effective solutions to inequality through tools for financial management and sustainability as well as improved access to information, better education and training, higher impact and great returns on investment.

Our work is centred around equity and access: we light fires that equip and inspire people to be the architects of their own lasting change. Identifying inequalities, gaps in provision, and new opportunities is crucial to making that work as impactful it can be for the problems that we’re trying to solve. That’s why we are campaigning for better regulatory data in the charity sector. This has to happen now. Low levels of transparency and accountability are a major risk for every stakeholder in civil society, but small charities with fewer resources are hit especially hard by secrecy and in-group thinking.

With the closure of the Small Charities Coalition, it’s now more important than ever to ensure that #SmallButVital charities have a level playing field on which to do their brilliant work. If you want to see a stronger, more effective, and more transparent charity sector, can I urge you to join the #OperationTransparency movement by signing and sharing the our open letter to the Charity Commission below.

With best wishes and courage for the mission,


Dear Helen Stephenson,

The charity sector has a massive diversity problem. Nowhere is this more evident than at the senior management and board level.

About half of trustee recruitment still happens by referral from existing trustees, according to a survey by the insurance specialist Ecclesiastical from late 2021. The Charity Commission’s own research in 2017 estimated that about 92% of trustees are white and two thirds are male. ACEVO’s 2021 Pay and Equalities Survey found that only 25% of respondents were happy with the ethnic diversity of their boards.

Further, the data that is publicly available is often incomplete and out of date. What proportion of funding is being allocated to organisations led by people of colour? What proportion of charities are led by people with lived experience in their areas of work? How many women-led charities exist? How many disabled trustees are there? The available indicators paint an incomplete but bleak picture, and ultimately, unlike in the public sector and (under new Financial Conduct Authority rules) the private sector, we just don’t know.

The Charity Commission is well aware of this problem, and yet they’ve decided to do nothing. Their 2017 Taken on Trust report, written alongside the Cranfield Trust, City, University of London’s business school, NCVO and the DCMS, contains two specific recommendations that would have addressed the issue directly. This is what it says:

We recommend that the Charity Commission should capture additional information on trustees:

  • Capture information on the gender of trustees. It is apparent from discussion of the survey findings that diversity is an important policy issue, so information on gender is also important. The most straightforward way would be to request this information in aggregate form in the annual return, but consideration could also be given to capturing it for individual trustees.
  • Introduce a requirement to report on board diversity in the annual return for all charities with an annual income in excess of £500k.
The Charity Commission

Taken on Trust: The awareness and effectiveness of charity trustees in England and Wales, 2017

In late 2021 we asked the Charity Commission what they had done to action these proposals in the four years since the report was published. This is what they said:

[…] no decisions have yet been taken with respect to the issue covered by these recommendations.

The Charity Commission

FOI Request, 17 December 2021

The consequences of the current lack of diversity are real: they result in poorer outcomes for the communities that we’re seeking to serve. Organisations with more diverse boards are more resilienteffective, and creative. Donors and grant-makers should be able to see whether or not charitable organisations are governed in accordance with their values and that people with lived experience have a seat at the table. Intersectional discrimination in the charity sector is a complex and multi-faceted problem that demands meaningful change on many fronts. Increasing transparency won’t solve the leadership diversity problem on its own, but at the end of the day, you can’t change something that you can’t measure.


We’re proposing that all organisations which file an annual return to the Charity Commission should be required to include standardised data tables on the diversity of their board and senior leadership, including the characteristics currently proposed for reporting by listed companies under new Financial Conduct Authority rules CP21/24 (gender and ethnicity), and also including other protected characteristics under the Equality Act 2010. Like the tables proposed by the FCA, each field should contain only percentages to ensure that individual trustees’ protected characteristics are not identifiable, and should include a ‘Not specified/prefer not to say’ option that will allow organisations to withhold disclosure entirely if they have security concerns or other reasons for doing so. Our proposal follows a recommendation by Voice4Change and ACEVO towards “better regulation for DEI [Diversity, Equality and Inclusion]” and “strengthened DEI requirements on charity reporting”.

This step will strengthen governance across the sector in a number of important ways. It will boost public trust in charities by increasing transparency; give investors and donors the means of holding organisations to their senior leadership diversity commitments, and holding funders to account for the diversity of their funding decisions; enable targeted, effective interventions to address historic funding inequalities; and encourage organisations which do not currently measure board diversity to reflect on their performance in this area.

The charity sector, of all the facets of society, should be at the forefront of transparency and good governance. It’s time for the Charity Commission to step up to its objectives and close the data gap.


Sign the Open Letter

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We, the undersigned, hereby endorse this proposal. The Charity Commission, in the collective interests of our civil society and in accordance with democratic principles of accountable governance, should implement it as soon as practically possible.


  • Action for Trustee Racial Diversity – Malcolm John, Founder
  • All Nations Christian College – Andy Dipper, Principal & Chief Executive
  • Black Fundraisers UK – Kemar Walford, Chair
  • Black Heroes Foundation – Joyce Fraser, Chair of Trustees
  • Charity Excellence – Ian McLintock, Founder
  • Charity So Straight – Kevin Taylor-McKnight, Founder
  • Charity So White – Jonathan Cornejo, Organiser
  • Clear Thinking Consultancy – Kita Ikoku, Director
  • Co-op Foundation – Nick Crofts, CEO
  • Community Watch Initiative Sierra Leone – Community Watch Initiative Sierra Leone, CEO
  • Do IT Foundation – Jamie Ward-Smith, CEO
  • Getting on Board – Penny Wilson, CEO
  • I.G. Advisors – Emily Collins-Ellis, CEO
  • JMB Consulting – Martha Awojobi, CEO
  • Manchester BME Network – Fiona McInroy, Director
  • Money4YOU – AmickyCarol Akiwumi, Founder/CEO
  • New Philanthropy Capital – Dan Corry, Chief Executive
  • Race on the Agenda – Maurice Mcleod, CEO
  • Reach Volunteering – Janet Thorne, CEO
  • South Asian Health Action – Kirit Mistry, Chair and Founder
  • Step Up Hub – Harbi Farah, Director
  • Thank U Charity – Sally Baffour, Founder/CEO
  • The Charity Excellence Framework – Ian McLintock, Founder
  • The Good Trouble Collective – James Murphy, Director
  • The Kids Network – Sarah Woodcock, CEO & Founder
  • Tooting Graveney Daycare Centre – Fitzroy Beckford, Chairman
  • Trustees Unlimited – Ian Joseph, Managing Director
  • Voice4Change England – Kunle Olulode, Director
  • Watford Asian Community Care – Hemant Mistry, Chairperson
  • Youel Murray Ltd – Fiona Murray, Director of Foundations & Nonprofits
  • Young Kensington and Chelsea (YPF) – Anita Richards, Fundraising and Development Manager
  • Young Trustees Movement – Amelia Ireland, on behalf of YTM Ambassadors
  • Elizabeth Balgobin – Consultant
  • AC Baker – Research and Policy Advisor
  • Helen Mccartan – Fundraising manager
  • Hugh Stultz – VCS trainer, fundraiser
  • Lucy Straker – Head of Communications/Activitist
  • Femi Owolade – Research Associate
  • Vishnee Sauntoo – Charity Trustee and Communications leader
  • Robb Masters – Former Chair of the Board of Trustees at The Vegan Society
  • Isobel Michael – Fundraiser and Trustee
  • Gabriel Ayeh-Fianko – International Programs Officer
  • Melville Matroos – Individual
  • Suzanne Flanegan – Student
  • Natsayi Sithole – Chief of Staff
  • Paul Johnson – Consultant
  • Andy Gregg – Individual
  • Liz Pepler – Director, Embrace Finance
  • Daniel King – Professor of Organisation Studies, Nottingham Trent University
  • Lisa Smith – Relationship Manager and Charity Trustee
  • Mike Allen – Trustee Recruitment & Liaison
  • Martin Lord – Charity Leader and Non Exec
  • Davinia Batley – Fundraising & Communications Lead
  • James Fitzpatrick – Charity Director
  • Dipesh Pandya – Artist Activist
  • Veronica Kararwa – Director
  • Tracy Saunders – Individual
  • Edwin Viegas – Insurance Specialist
  • Michele Fox – Individual
  • Carolyn Mann – Customer Experience and Insight Manager/Trustee
  • Clare Muthurajah – Lead Practitioner – Brighton & Hove Children’s Services
  • Sarah Gosling – Charity Governance Consultant
  • Natasha Raudon – Academic
  • Bryan Rossi-Anderson – Solutionary / I BE Consultancy
  • Sian Prime – Lecturer
  • Louise Snelders – Head of Funding and Partnerships, Co-op Foundation
  • Claris D’cruz – Governance Consultant & Trainer

Signed on/after 4th July 2022

Letter sent to Charity Commission

  • Links, The Chesterfield & NE Derbyshire CVS & Action Ltd – James Lee, Chief Executive
  • Maurice Mcleod – Maurice Maurice Mcleod, CEO
  • Migrants’ Rights Network – Fizza Qureshi, CEO
  • Team Tilt Ltd – Eleanor Gibson, Founder and coach
  • Michael Rogerson – Past trusteeship
  • Nina Singh – Finance Officer
  • Paula Khan – Clinical Counselling Manager
  • Laura Stevens – Project Manager
  • Ruth Smith – PhD graduate / VAWDASV Trainer / Guest Speaker
  • Red Godfrey-Sagoo – CEO

Statement of Support

As the UK charity sector adapts to new challenges and opportunities following the COVID-19 pandemic, it is more important than ever to make our recovery work for everyone. We are proud of the way in which civil society has responded to people’s needs, worked closely with both government and the private sector, and found new ways to reach service users during this difficult time.

Trustees play a vital role in charity governance and the Commission’s recent measures to provide additional advice and resources on trustee governance have been both welcome and impactful. However, as the 2017 Taken on Trust report noted, diversity remains low, and there is “clearly a need to promote greater diversity within charity trustee boards.” In this context, we welcome the Commission’s commitment in the 2021-22 Business Plan to improving its use of data.

Efforts to improve data capture and access around trustee diversity are vitally important. Following the Financial Conduct Authority’s policy statement on this issue, we support the inclusion of such data in the Register of Charities as suggested by the #OperationTransparency campaign. This will not only strengthen the Commission’s core public confidence and accountability objectives, but will also facilitate greater insights and swifter innovation at the cross-section of charity governance, data governance, and social entrepreneurship.

Trustee diversity is a complex and challenging area and we recognise that there is more work to do. We are committed to working with the Charity Commission, infrastructure bodies, and others across the sector to ensure that the United Kingdom continues to lead the way in transparency and innovation.

  • Charities Aid Foundation – Neil Heslop, CEO


27 February 2023

Charity Commission’s Consultation Response Leaves Unanswered Questions on Diversity Data Gap: We welcome the Charity Commission’s update on its position with respect to diversity in the charity sector as part of a recent consultation response. However, we struggle to understand the concerns it articulates around diversity data reporting in the Annual Return. Read more

8 December 2022

The campaign reaches its 75th verified signature.

20 October 2022

Re-imagining finance and funding for BAMER-led organisations, with James Lee (City Bridge Trust), Liz Pepler (Embrace Finance), James Murphy (The Good Trouble), Ali Habib (Action Funder), Cris Ferreira (National Lottery Heritage Fund), Julie Pal (CommUNITY Barnet), and AmickyCarol Akiwumi (Money4YOU). Read more

28 September 2022

Charity Commission responds to #OperationTransparency: Money4YOU received a formal response from the Commission, dated 8th August, acknowledging the severity of the issue and committing our proposal to consideration. The Commission has made no policy commitments, but we hope its openness to addressing the issue will encourage others affected and interested to continue adding their own views. Read more

7 July 2022

Earning Trust: How do we Design Fair, Impactful and Equitable Charity Diversity Data? (watch here) with Jane Ide OBE , CEO at ACEVO, Paul Amadi MBE, Chief Supporter Officer at British Red Cross, Maurice Mcleod, CEO at ROTA, and AmickyCarol Akiwumi MBE FRSA FCIOF, CEO and Founder of Money4YOU

4 July 2022

Letter Sent to the Charity Commission

23 June 2022
24 May 2022

Bridging the Data Gap: From Transparency to Decolonisation (watch here) with AmickyCarol Akiwumi MBE, Martha Awojobi, Malcolm John, Penny Wilson, Kunle Olulode, Daniel King

13 May 2022

The Charity Commission’s 2022-23 Business Plan is published. Like the Statement of Strategic Intent for 2018-23, it makes no mention of the words “equality”, “diversity”, “inclusion”, or “lived experience.”

22 March 2022

After repeated queries, the Charity Commission publishes a blog post about data which does not match the text published in Civil Society.

20 March 2022

The campaign reaches its 50th verified signature.

17 March 2022

The Charity Commission publishes a policy statement in Civil Society Governance & Leadership, which has a minimum £105 paywall. Whilst welcoming public dialogue with the regulator, we call on the Commission to make the article freely available with immediate effect, along with an explanation of why it chose to conduct stakeholder engagement in this exclusive way.

8 March 2022

The Co-op Foundation becomes the first grant-maker to sign #OperationTransparency.

28 February 2022

Five major trusteeship organisations sign the open letter, including Getting On Board, Trustees Unlimited, Reach Volunteering, Action for Trustee Racial Diversity, and the Young Trustees Movement.

24 February 2022

#OperationTransparency launches, gathering 12 signatures in its first 24 hours.



The latest #OperationTransparency panel brings leading voices from the BAMER-led UK voluntary sector together to create a practical vision of diversity data transparency. In this informative, future-focused discussion, we’ll cover the implications of charity diversity data for politics, data privacy, funding allocation, recruitment, and public trust. We’ll also discuss precedents and future battlegrounds on open government data, like the gender and ethnicity pay gaps, beneficial ownership, and grant allocation, to paint a broader picture of accountability.

⏯️ Hold funders and executives to account on equality, diversity and inclusion! Have you ever tried to find out exactly what proportion of funding is being allocated to organisations led by people of colour? Or what proportion of charities are led by people with lived experience in their areas of work? How about finding out how many women-led charities exist or how many disabled trustees there are in the UK?

An interactive panel discussion on how we got to this point, the role of the regulator in these kinds of questions, and how they affect trust and accountability in the sector as a whole.


4th July 2022 – Increase charities’ diversity data reporting requirements, Commission told (Civil Society)

4th July 2022 – Coalition calls for regulator to add reporting requirements to help address ‘massive diversity problem’ (Third Sector)

4th July 2022 – Campaigners formally approach regulator to call for diversity reporting in annual returns (Charity Times)

4th July 2022 – Diversity data desperately needed, sector urges Charity Commission (UK Fundraising)

4th July 2022 – Increase charities’ diversity data reporting requirements, Commission told (Civil Society)

28th September 2021 – Charity trustees do not reflect the communities that they serve, says regulator (Civil Society)

28th September 2021 – Trustees ‘do not reflect the make up of the communities they serve’, warns regulator (Charity Times)

28th September 2021 – Charity Commission responds to #OperationTransparency on need for diversity data (UK Fundraising)


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