The Charity Finance Group and Charity Tax Group have expressed concerns about some of the key proposals to make it easier for donations through intermediaries to attract Gift Aid, in response to a consultation which closed yesterday.

HM Revenue & Customs has proposed that donors should be allowed to make one Gift AId declaration a year for each digital donations platform they use, instead of making a fresh declaration every time they donate, in a technical consultation which closed yesterday.

But CFG and CTG said they were concerned the proposed changes would not cover text giving, which currently has low levels of Gift Aid take-up.

And they both said they were opposed to the government’s plans to require an “annual statement” to be sent to all donors using the single declaration, and to require “positive authorisation” from donors to allow their details to continue to be used.

“We strongly oppose the introduction of annual statements to be emailed or written for donors that make use of this new process,” CFG said in its response.

“We believe that this new statement will confuse donors, runs counter the existing direction of travel to reduce unsolicited communications to donors, separates Gift Aid from the donation and could lead to more negative views around Gift Aid .

“All of these risks are being ventured with little or no evidence of the improvements that would result from the introduction of the annual statement. Without an evidence base, this regulation should be pursued.

“We strongly urge the government to reconsider the annual statement regulations, and amend them to give every donor the right to access an account where all their donations, Gift Aid claims and information about claiming higher rate relief can be held.”

CTG said in its response that with the exception of retail Gift Aid, no other form of giving currently requires annual Statements or positive authorisation.

“Any attempt to broaden out the use of annual statements and “positive authorisation” to all donations would be counter-productive due to the additional administrative burden with the likelihood of donor apathy leading to a substantial value of eligible donations no longer being Gift Aided,” the CTG said.