We highlight, however, the following issues as particular areas of concern regarding proposals forwarded in the Discussion Paper:
• Reforms focussing on individual activities undertaken by charities, as opposed to their overarching purpose
• By extension, the possible erosion of the charities’ rights to undertake advocacy
• The introduction of additional review and audit processes to investigate continual compliance with DGR requirements over time, and
• Greater focus on the need to address other areas of regulation to create certainty and trust in the regime.
Our views regarding these issues are elucidated further below.