Aggressive fundraising tactics: where is the line between persistence and pressure?

Data sharing between charities, high-frequency asks, and pressure on vulnerable donors have driven major regulatory reform. The tension between maximising income and respecting supporters remains unresolved.

By Tom Neill-Eagle

The debate in brief

Charities exist to do good, but they need money to do it. That imperative creates a permanent tension: every pound not raised is a service not delivered, a person not helped. Fundraisers operate under real pressure to maximise income, and the methods that generate the most revenue are not always the ones that treat supporters best.

The problem surfaced dramatically in 2015 when the death of 92-year-old poppy seller Olive Cooke exposed the scale of data sharing between charities and the volume of solicitations some donors received. Cooke was receiving up to 267 charity mailings per month. The subsequent Etherington Review and creation of the Fundraising Regulator in 2016 reshaped the regulatory landscape, but the underlying question has not gone away. How often is too often to ask? When does persistence become pressure? And who is responsible when vulnerable people are harmed by fundraising that, on paper, follows the rules?

Quick takeaways

QuestionAnswer
What counts as aggressive fundraising?There is no single legal definition. The Fundraising Regulator's Code prohibits unreasonable persistence, undue pressure, and exploitation of vulnerability. Context matters.
Is it legal for charities to share donor data?Only with explicit consent under UK GDPR. Before 2018, charities routinely shared and traded donor lists with far less oversight.
How many fundraising complaints are there each year?The Fundraising Regulator received 1,284 cases in 2024/25, with telephone and door-to-door methods generating disproportionate volumes.
Can I stop charities contacting me?Yes. The Fundraising Preference Service lets you stop contact from specific charities. You also have rights under UK GDPR to object to direct marketing.
What protections exist for vulnerable donors?The Code of Fundraising Practice requires charities to take reasonable steps to identify and protect people in vulnerable circumstances from undue pressure to give.

The arguments

Fundraising is a duty, not a luxury

Charity leaders and fundraising professionals argue, with some justification, that raising money is not optional. Charities have legal objects to fulfil, beneficiaries who depend on their services, and staff whose livelihoods rely on income targets being met. A charity that under-fundraises is not being virtuous; it is failing the people it exists to serve.

From this perspective, persistent fundraising is part of the job. Most people who receive a charity mailing or a telephone call are not distressed by it. Response rates to direct mail are typically between 1 and 3%, which means the overwhelming majority of recipients simply ignore the ask. The small number of people who find it intrusive are, in the utilitarian calculus, outweighed by the funds raised for beneficiaries. Fundraising professionals also point out that donor relationships are built over time, and that a single ask is rarely enough: research consistently shows that donors give more when asked more than once, and that lapsed donors can often be reactivated through follow-up contact.

The Chartered Institute of Fundraising has argued that the sector's problem is not too much fundraising but too little. UK charitable giving as a share of GDP has been broadly flat for decades, and many charities, particularly smaller ones, lack the resources to fundraise effectively at all. Restricting the methods available to those that do fundraise risks concentrating income further among the largest organisations.

The donor's experience is what matters

Critics counter that the donor's experience, not the charity's intention, is the proper measure of whether fundraising is aggressive. A telephone call that feels like a friendly check-in to one person may feel like an intrusion to another. A direct mail pack that one household opens with interest may cause distress in another where the recipient is elderly, confused, or recently bereaved. The same fundraising method can be perfectly acceptable in one context and harmful in another.

The evidence from the Olive Cooke case and from the Fundraising Regulator's subsequent investigations revealed systemic problems that went beyond individual bad actors. Charities were routinely sharing and trading donor data through list brokers, meaning that a single donation could trigger contact from dozens of organisations the donor had never heard of. The sheer volume of solicitations some people received was not the result of one charity being too persistent but of an entire ecosystem operating without adequate checks on cumulative impact.

The concept of vulnerability is central to this argument. The Fundraising Regulator's guidance on treating donors fairly notes that vulnerability is not a fixed characteristic but a state that anyone can experience. Bereavement, cognitive decline, financial hardship, loneliness, and mental ill health can all make a person more susceptible to pressure. A fundraising approach designed for the general population may cause real harm when it reaches someone in a vulnerable state, and charities cannot always know who is and is not vulnerable at any given time.

The structural problem of data and incentives

A third strand of the debate focuses not on individual interactions but on the structural incentives that drive aggressive practices. When fundraising teams are set income targets, when agencies are paid on commission, when donor databases are treated as assets to be monetised, the system pushes toward more contact, more asks, and more pressure. Individual fundraisers may behave impeccably, but the aggregate effect of multiple charities all optimising for response rates is a donor experience that can feel relentless.

Data sharing was the clearest example. Before UK GDPR came into force in May 2018, many charities shared supporter data with other organisations either directly or through commercial data brokers. The Information Commissioner's Office investigated several major charities in 2016 and 2017 and found widespread non-compliance with data protection principles. The RSPCA, the British Heart Foundation, and Macmillan Cancer Support were among those found to have shared donor data without adequate consent, resulting in enforcement actions and significant reputational damage.

The structural argument suggests that regulation must address systems, not just individual behaviour. Banning one tactic while leaving the underlying incentive structures intact simply displaces the problem.

The evidence

The Fundraising Regulator's complaints data provides the most systematic picture. In 2024/25, the Regulator received 1,284 cases, with the most common issues being frequency of contact, failure to honour opt-out requests, and pressure to give. Telephone fundraising and direct mail continue to generate disproportionate complaints relative to their share of total fundraising activity.

The ICO's 2016-17 investigations into charity data sharing found that at least 11 major charities had been sharing donor data in ways that breached the Data Protection Act 1998. The RSPCA was fined £25,000 and the British Heart Foundation was fined £18,000. The ICO noted that data had been shared with wealth-screening companies to identify high-value donors, and that in some cases individual donors had been contacted by charities they had never supported, based entirely on shared data.

Research by the Charity Commission on public trust has consistently identified fundraising practices as a significant factor in public attitudes. The Commission's 2025 Public Trust and Confidence in Charities report found that 26% of people who reported declining trust cited concerns about how charities raise money, making it one of the top three drivers of distrust alongside executive pay and the proportion of funds reaching beneficiaries.

A 2019 study by the University of Plymouth examined the experiences of older donors and found that many felt unable to refuse requests from charities they had previously supported, describing a sense of obligation and guilt that fundraising communications were designed to activate. The researchers argued that conventional consent mechanisms were inadequate for people whose decision-making capacity may fluctuate.

The Fundraising Preference Service, launched in 2017, processed over 19,000 requests in its first year and has continued to receive steady volumes, suggesting that a meaningful number of people feel they cannot manage charity contact through normal opt-out channels alone.

Current context

The regulatory framework governing fundraising in England, Wales, and Northern Ireland is significantly stronger than it was a decade ago. The Fundraising Regulator's Code of Fundraising Practice, last updated in 2025, sets clear standards on frequency of contact, treatment of vulnerable donors, and use of third-party fundraisers. UK GDPR has fundamentally changed data-sharing practices, and the era of routine donor list trading is effectively over.

However, new challenges have emerged. Digital fundraising channels, including email, social media advertising, and SMS, are subject to the same regulatory principles but are harder to monitor. The Fundraising Regulator has noted an increase in complaints about digital and online fundraising methods, and the sheer volume of online charitable appeals, particularly around emergencies and disaster responses, can create a digital equivalent of the mailbox problem Olive Cooke experienced.

The cost-of-living pressures from 2022 onwards have added a new dimension. Charities face rising demand for their services at the same time as donors face squeezed household budgets. The temptation to ask harder, ask more often, and push for higher gift values is real. The Fundraising Regulator issued specific guidance in 2023 reminding charities that cost-of-living pressures may make donors more vulnerable to pressure and that fundraising approaches should be adjusted accordingly.

The broader question of ask frequency remains largely self-regulated. The Code of Fundraising Practice does not specify a maximum number of contacts per year; instead it requires charities to consider whether their contact is "unreasonably persistent." What counts as unreasonable is a matter of judgement, and charities with sophisticated donor relationship management systems tend to manage this better than those that do not.

Last updated: April 2026

What this means for charities

Charities that take fundraising ethics seriously should start with their data. Do they know how many times each supporter is being contacted across all channels? Many organisations discover, when they audit this, that the cumulative contact volume is far higher than any single team realised, because email, direct mail, telephone, and events teams each operate their own schedules.

Vulnerability policies need to be practical, not aspirational. A written policy that fundraisers have never been trained on achieves nothing. The best practice in the sector involves scenario-based training, clear escalation routes for fundraisers who encounter someone they believe may be vulnerable, and regular review of complaints and cancellation data for patterns that suggest systemic problems.

Governance matters. Trustees should be asking how the charity monitors its fundraising, what the complaints rate is, and how it compares to sector benchmarks. They should see mystery shopping results and cancellation data, not just income figures. The Charities (Protection and Social Investment) Act 2016 places a specific duty on trustees to ensure that fundraising is conducted in a way that protects donors.

The strategic case for restraint is underappreciated. Charities that bombard supporters with appeals may maximise short-term income but risk eroding the relationship that sustains giving over years and decades. Lifetime donor value, not campaign response rate, is the metric that should drive strategy.

Common questions

What is the Fundraising Regulator?

The Fundraising Regulator is the independent body that sets and enforces fundraising standards for charitable organisations in England, Wales, and Northern Ireland. It was established in 2016 following the Etherington Review, replacing the self-regulatory Fundraising Standards Board. It maintains the Code of Fundraising Practice and operates the Fundraising Preference Service. Scotland has a separate regime under the Office of the Scottish Charity Regulator.

How do I complain about charity fundraising?

You can complain directly to the charity first. If the charity does not resolve your complaint, or if you prefer to go directly to the regulator, you can contact the Fundraising Regulator through its website. The Regulator can investigate complaints, require charities to change their practices, and publish investigation findings. For data protection concerns, you can also complain to the Information Commissioner's Office.

Can charities still share my data with other organisations?

Under UK GDPR, charities can only share your personal data with other organisations if they have a lawful basis to do so and, in most fundraising contexts, this means your explicit consent. The era of routine data sharing and list trading that characterised the sector before 2018 has largely ended. If a charity is sharing your data without your consent, this is likely a breach of data protection law.

What protections exist for elderly or vulnerable donors?

The Code of Fundraising Practice requires charities to take reasonable steps to identify and protect people in vulnerable circumstances. This includes training fundraisers to recognise signs of vulnerability, having procedures for pausing or stopping contact when concerns arise, and not exploiting a donor's sense of loyalty or obligation. The Charities (Protection and Social Investment) Act 2016 also gives the Charity Commission powers to act against charities that fail to protect vulnerable people from undue fundraising pressure.

Is there a legal limit on how often a charity can contact me?

There is no specific legal maximum. The Code of Fundraising Practice requires that contact must not be "unreasonably persistent," but this is a judgement call rather than a fixed number. If you want to reduce or stop contact, you can tell the charity directly, use the Fundraising Preference Service, or exercise your rights under UK GDPR to object to direct marketing.

Has fundraising behaviour actually improved since 2015?

The evidence suggests meaningful improvement. Complaints to the Fundraising Regulator have stabilised rather than increased, data-sharing practices have been transformed by UK GDPR, and many charities have invested in vulnerability policies and donor care standards. But problems persist, particularly around telephone fundraising and digital channels, and the structural incentives that drive aggressive fundraising have not disappeared.

Key sources and further reading

  • Regulating Fundraising for the Future (Etherington Review) -- Sir Stuart Etherington, NCVO, September 2015. The independent review that recommended creating the Fundraising Regulator.

  • Charities (Protection and Social Investment) Act 2016 -- UK Parliament. Established reporting requirements on fundraising practices and gave the Charity Commission enhanced powers regarding fundraising.

  • Code of Fundraising Practice -- Fundraising Regulator, updated 2025. The standards framework governing charitable fundraising in England, Wales, and Northern Ireland.

  • Public Trust and Confidence in Charities 2025 -- Charity Commission / Gov.uk. Data on public attitudes toward charity fundraising and the factors driving trust and distrust.

  • Fundraising Regulator Annual Complaints Report 2024/25 -- Fundraising Regulator. Breakdown of complaints by fundraising method and issue type.

  • ICO Enforcement Actions on Charity Data Sharing -- Information Commissioner's Office, 2016-2017. Findings and penalties relating to donor data sharing by major UK charities.

  • Fundraising Preference Service -- Fundraising Regulator, launched 2017. The mechanism allowing individuals to stop contact from specific charities.

  • Older People's Experiences of Charitable Giving -- University of Plymouth, 2019. Research on how fundraising practices affect elderly donors and the adequacy of consent mechanisms.

Researched and drafted with Pippin, Plinth's AI research tool. All statistics independently verified.