Case Study: Stoke Air Ambulance CIO – key lessons for fundraising charities

The Fundraising Regulator’s investigation report, published on 4 February 2026, into Stoke Air Ambulance’s fundraising practices, and the Charity Commission’s decision to launch a follow-on statutory inquiry, highlight a number of key lessons for charities involved in public fundraising. 

The Fundraising Regulator’s investigation

The charity’s stated aim was to establish an air ambulance service for Stoke and its surrounding area. The Fundraising Regulator began investigating the charity’s fundraising activities in 2025 after receiving complaints over its face-to-face and online fundraising. 

The regulator found there had been multiple breaches of the Fundraising Code of Practice: 

• It found that the charity had used misleading images and text on its website which suggested it was already operating a functional air ambulance service, when in fact at the time of the complaints, the charity did not have any aircraft or clinicians.
• The charity had made misleading and unfairly critical statements about other charities. The charity’s website and social media posts implied that other local air ambulance charities were less responsive to emergencies in the Stoke area, and that another charity had prevented it from flying to local events, intimidated it and deceived the public about where its own service operated from – none of which Stoke Air Ambulance could substantiate with evidence.
• The charity had encouraged donors using payroll giving to change their donations to benefit the charity instead of other similar charities, which was a clear breach of the code.
• The regulator had also received complaints about social media posts by the charity that it would fly an aircraft to local events, to encourage potential donors to attend. The charity also offered a flight as an incentive for volunteers to collect donations. Although the charity had planned to lease a helicopter for this purpose, it was unsuccessful. The regulator found the claims were misleading, as the charity did not have the means to fulfil them when they were made. 

The charity had made some updates to its website and social media posts during the investigation. The regulator’s final recommendations were that the charity cease unfairly criticising other charities, remove any remaining misleading or unsubstantiated claims, and make clear its progress towards its goals to potential donors. 

Importantly, the regulator also recommended that the charity contact all its regular donors to inform them of the regulator’s decision, to check that they had not been impacted by any misleading fundraising. The charity agreed to comply with all the recommendations. 

Charity Commission involvement 

More significantly, perhaps, on the same day that the regulator’s decision was published, the Charity Commission announced it was launching a statutory inquiry into the charity. The Commission’s focus will be the trustees’ compliance with their legal duties regarding the charity’s administration, governance and management. As well as the charity’s fundraising arrangements, the Commission was concerned about potential conflicts of interest and payments to a company connected to a trustee, the proportion of its income being applied for charitable purposes, and whether its aim of operating an air ambulance service was viable. 

Key takeaways 

The case provides several important lessons for charities involved in public fundraising, and a reminder of key aspects of the code: 

• It is essential that fundraising materials are not misleading. In particular, they must be sufficiently clear that donors are not likely to believe that their donations are supporting ongoing activities that do not yet exist.
• Fundraising charities must not forget that they need evidence to prove any claim made in their fundraising materials which is likely to be taken literally by a donor. They must also ensure that, if they make any promise as part of a fundraising campaign, they have the means to deliver the promise when it is made.
• Finally, the code makes it clear that it is not acceptable to unfairly criticise other individuals or organisations, or to encourage donors to cancel or change existing donations in their favour. 

The case highlights the risks of regulatory involvement. The case was one of four investigation summaries published by the Fundraising Regulator in February 2026, compared to eight for the whole of 2025 – though it remains to be seen whether this heralds the start of a period of increased enforcement. It is, though, a reminder that the Charity Commission is prepared to use its statutory powers to reinforce the non-statutory work of the regulator, and that ensuring compliance with the code to avoid the risk of escalation to regulators is paramount.