# Matched Giving Policy Template — 2026 UK SMB Guide > A practical matched giving policy template for UK SMBs — clauses, eligibility, caps, exclusions, approval workflow, and a copy-pasteable skeleton. Author: Workplace Giving Editorial Published: 2026-05-10 Pillar: matched-giving Canonical: https://workplacegiving.co.uk/matched-giving/matched-giving-policy-template/ --- A **matched giving policy** is the short document that turns a vague "we match donations" commitment into something your finance team can actually budget for and your auditors won't query. Most UK SMBs running [matched giving](/matched-giving/) skip writing one for the first six months — and then regret it when the first awkward case lands on someone's desk (a staff member wants to match a donation to a political campaign, or to a US-based charity, or has submitted a £2,000 receipt against an undefined cap). This guide walks through the clauses a UK SMB matched giving policy should contain, what each clause is for, and ends with a copy-pasteable skeleton you can adapt in an afternoon. ## Why a written policy matters (more than people think) There are three audiences for a matched giving policy, and they all need slightly different things from it: 1. **Employees** want to know what's matched, how to claim, and how long it takes 2. **Finance and HR** want clear eligibility rules so they aren't making case-by-case judgement calls 3. **Auditors and HMRC** want evidence that corporate donations are genuine charitable donations under [Part 6 of the Corporation Tax Act 2010](https://www.gov.uk/tax-limited-company-gives-to-charity) — not disguised remuneration, not personal donations by directors routed through the company, and not payments to organisations that aren't actually charities That third audience is the one most SMBs forget about. The risk isn't large at SMB scale, but a written policy with consistent application is the cheapest possible insurance against an HMRC enquiry asking why a £5,000 corporate donation to a charity that happens to be chaired by the managing director's spouse should be deductible from Corporation Tax. The answer ("we have a written matched-giving policy that applies to every employee, and this is a £500 match against a £500 personal donation by Sarah in accounts") is much easier than the alternative. ## The clauses your policy needs A good UK SMB matched giving policy is one to two pages. Anything longer is admin debt. The clauses below are the minimum viable set. ### 1. Purpose statement One paragraph. What is the programme for, who runs it, and what does the company commit to. This is mostly tone-setting, but it also pins down accountability — there should be a named role (HR Manager, Finance Director, People Lead) that owns the programme. ### 2. Eligibility — who can claim Standard practice in UK SMB policies: - All permanent employees, full-time and part-time, from day one of employment - Some firms add fixed-term contractors after three or six months - Most firms exclude self-employed contractors, agency workers, and non-executive directors Be explicit. A policy that says "employees" without defining the term will produce edge cases. ### 3. Eligibility — what charities qualify This is the clause that does the most work. The most common formulation is *"any charity registered with the Charity Commission of England and Wales, the Office of the Scottish Charity Regulator (OSCR), or the Charity Commission for Northern Ireland (CCNI)."* Optionally extend to: - **CASCs (Community Amateur Sports Clubs)** registered with HMRC — relevant if you want to match local sports club donations - **Charitable Incorporated Organisations (CIOs)** — already covered by Charity Commission registration - **Overseas charities** — note that [HMRC withdrew charitable tax reliefs for non-UK charities](https://www.gov.uk/guidance/charities-and-tax) from April 2024, so matches to EU/EEA or other overseas bodies get no Corporation Tax relief; most SMBs simply say "UK-registered charities only" and avoid the complexity ### 4. Exclusions — what won't be matched Most disclosed UK policies exclude: - **Political parties and political campaigns** — these are not registered charities, so this is clarification rather than restriction - **Donations where the employee receives a personal benefit** — e.g. raffle tickets, charity dinners with a meal element, sponsorship of the employee's own child's school trip - **Donations to organisations of which the employee is a trustee or principal beneficiary** — keeps the programme away from related-party transaction territory - **Membership fees and subscriptions** even where the body is a charity (e.g. National Trust, RSPB membership) - **School fees, tuition fees, or building funds at private schools** — even where the school operates as a charity, HMRC treats these as benefits-in-kind The religious-purpose question is the contested one. A widely-used formulation: *"Donations to religious organisations are eligible where the donation supports community welfare, education, or charitable services. Donations whose primary purpose is the advancement of religion (e.g. capital fundraising for places of worship) are at the discretion of the Programme Owner."* This gives you cover to match a donation to a foodbank run by a church, while leaving room to decline a £500 match towards a church roof appeal if that's where the company wants to draw the line. ### 5. Match ratio and cap The two numbers everyone reads first. See our [matched giving ratios and caps](/matched-giving/matched-giving-ratios-and-caps/) deep-dive for the full thinking — for a policy document, you need: - The standard ratio (almost always 1:1 for UK SMBs) - The annual per-employee cap (typically £100–£1,000) - Whether there's a higher special-campaign ratio (e.g. 2:1 during a Charity of the Year drive — see [Charity of the Year](/charity-of-the-year/)) - A minimum donation threshold (commonly £10 or £25 per claim to keep admin tractable) - A statement that unused allowance does **not** roll over year-to-year ### 6. Evidence requirements What employees must submit: - The name and registered charity number of the recipient charity - Proof of donation — a receipt, JustGiving page link, Payroll Giving Agency confirmation, or bank statement entry - The donation date and amount - A short statement that the donation has been made and is not the subject of any other employer match (some employees have side businesses) For [Payroll Giving](/payroll-giving/) donations, the Payroll Giving Agency's monthly statement is sufficient evidence. For other channels, a receipt or platform confirmation is standard. ### 7. Approval workflow For SMBs, the workflow should be boring. Something like: 1. Employee submits claim via the form/portal/email 2. HR or Finance verifies the charity is UK-registered (check the [Charity Commission register](https://register-of-charities.charitycommission.gov.uk/)) 3. Finance processes the match payment within X days 4. Programme Owner reviews aggregate spend monthly against budget Service-level commitment matters more than people realise. *"We aim to process matches within 30 days of claim"* is fine for SMBs. Anything slower starts to dent participation; staff lose faith and stop submitting. ### 8. Tax and accounting A short clause confirming that: - The corporate match is treated as a charitable donation under Part 6 CTA 2010 - The employee's original donation is **their** donation, and Gift Aid (if applicable) is theirs to claim - The employer does **not** claim Gift Aid on the matched portion — see our [tax treatment of matched giving](/matched-giving/matched-giving-tax-treatment-uk/) guide This protects against a common misunderstanding where employees assume the company is "topping up" their Gift Aid claim. ### 9. Privacy and data handling Donation data is special category in some interpretations (it can reveal religious or political belief by inference). Most SMB policies handle this by: - Storing donation records only for the period required for tax record-keeping (HMRC requires 6 years for corporate records — see [HMRC company record-keeping](https://www.gov.uk/running-a-limited-company/company-and-accounting-records)) - Restricting access to HR and Finance - Not publishing individual donation amounts internally (aggregate-only reporting is fine) ### 10. Review cycle State explicitly when the policy will be reviewed — annually is standard. Include a version number and "next review" date. This is the single cheapest thing you can do to make the policy look professional, and it protects you from the awkward situation of a policy quietly going stale for three years. ## The copy-pasteable skeleton Adapt the below to your firm's voice and circumstances. **This is a template, not legal advice** — run it past your finance team and, if matched giving is going to be a material company expense, your accountant. --- ### [Company Name] Matched Giving Policy **Version:** 1.0 **Owner:** [Role — e.g. People Director] **Last reviewed:** [Date] **Next review:** [Date] **1. Purpose** [Company Name] supports employees who give to UK registered charities by matching their personal donations. This policy sets out who can claim a match, what donations qualify, how much we match, and how to submit a claim. **2. Eligibility** This policy applies to all permanent employees of [Company Name], full-time and part-time, from their first day of employment. Fixed-term contractors with contracts of six months or longer are eligible after three months of service. **3. Qualifying charities** We will match donations to any charity registered with: - The Charity Commission of England and Wales - The Office of the Scottish Charity Regulator (OSCR) - The Charity Commission for Northern Ireland (CCNI) - HMRC as a Community Amateur Sports Club (CASC) **4. Exclusions** We will not match: - Donations to political parties, political campaigns, or lobbying organisations - Donations where the employee receives a personal benefit (raffle tickets, paid events, sponsorship of the employee's own family) - Donations to organisations where the employee is a trustee, founder, or principal beneficiary - Membership fees or subscriptions - School or university fees, building funds, or capital appeals at fee-charging educational institutions - Donations made before the employee's start date Donations to religious organisations are eligible where the supported activity is community welfare, education, or charitable services. Donations whose primary purpose is the advancement of religion are at the discretion of the Programme Owner. **5. Match ratio and cap** - Standard match ratio: **1:1** - Annual cap per employee: **£[amount]** - Minimum donation per claim: **£25** - Maximum donation per claim: **£[amount]** Allowance does not roll over between calendar years. Where a special campaign is running (e.g. our [Charity of the Year](/charity-of-the-year/) appeal), a 2:1 ratio may apply for a defined period; this will be announced separately. **6. Evidence required** Each claim must include: - The recipient charity's name and registered charity number - Proof of donation (receipt, JustGiving page link, Payroll Giving Agency confirmation, or bank statement entry) - The donation date and amount - A confirmation that the donation has not been matched by another employer **7. How to claim** Submit your claim within 90 days of making the donation via [link / form / email]. HR will verify the charity and forward the claim to Finance, who will process the match payment within 30 days of approval. **8. Tax treatment** Matched donations are made by [Company Name] as corporate charitable donations and are deductible from total taxable profits under Part 6 of the Corporation Tax Act 2010. Gift Aid does not apply to the corporate portion. The employee's original donation remains their donation; Gift Aid (if claimed) is theirs. **9. Data and confidentiality** Donation records are held by HR and Finance only, retained for the period required by HMRC for corporate tax records, and are not disclosed internally other than in anonymised aggregate. **10. Review** This policy is reviewed annually by the Programme Owner. --- ## Common edge cases and how to handle them The template above covers 95% of cases. Here are the ones that show up in years two and three: - **An employee runs a marathon and raises £3,000 via JustGiving.** Match against the employee's own contribution to that page, not the total raised. The other contributions are not the employee's donations. - **An employee donates via a workplace giving platform that already aggregates the match.** Decline the duplicate match — the platform did it. - **An employee leaves mid-year having claimed up to the cap.** Match honoured. They earned it as a benefit of employment. - **A director donates to a charity they are a trustee of.** Decline under clause 4 (related-party). Document the decision. - **A staff member's donation cleared December 28th, claim submitted January 5th.** Match against the year the donation cleared — be consistent. ## Pairing the policy with other workplace giving programmes A matched giving policy works best as one piece of a broader [workplace giving programme](/csr-esg-for-smbs/). It pairs naturally with: - A [Payroll Giving](/payroll-giving/) scheme — staff donate pre-tax, the company matches the gross donation - A [Charity of the Year](/charity-of-the-year/) campaign — the matching ratio can lift for the focal charity - Paid volunteer leave — see our [fundraising at work](/fundraising-at-work/) guide for how the two reinforce each other The single most common mistake we see is treating matched giving as a standalone HR perk. It works much harder when it's the cash arm of a coherent CSR commitment that also includes time off and active fundraising support. ## Sources - [HMRC: Tax when your limited company gives to charity](https://www.gov.uk/tax-limited-company-gives-to-charity) - [HMRC Company Taxation Manual — charitable donations relief (CTM09005)](https://www.gov.uk/hmrc-internal-manuals/company-taxation-manual/ctm09005) - [HMRC: Charities and tax](https://www.gov.uk/guidance/charities-and-tax) - [Charity Commission register of charities](https://register-of-charities.charitycommission.gov.uk/) - [Office of the Scottish Charity Regulator (OSCR)](https://www.oscr.org.uk/) - [Charity Commission for Northern Ireland](https://www.charitycommissionni.org.uk/) - [HMRC: Running a limited company — records](https://www.gov.uk/running-a-limited-company/company-and-accounting-records) - [NCVO Knowhow — fundraising compliance](https://www.ncvo.org.uk/help-and-guidance/) - [Charities Aid Foundation — UK Giving Report 2025](https://www.cafonline.org/insights/research/uk-giving-report/uk-giving-report-2025)