Gift Aid records: what your donation system must keep

This guide is about the record-keeping side of Gift Aid: what a system needs to hold so that a claim can be made, checked and defended. It is written by software engineers, not tax advisers. The rules are HMRC’s, they change, and your treasurer or accountant should confirm anything you rely on. HMRC’s own guidance for charities starts at Claiming Gift Aid as a charity or CASC, and the full rules are in chapter 3 of its detailed guidance notes.

What a declaration has to contain

HMRC does not require a set form, but it does require certain content. HMRC’s page on declarations says a declaration must name your charity, give the donor’s full name and full home address with postcode, describe the gift, and record that the donor agrees to Gift Aid being claimed and has paid at least as much Income Tax or Capital Gains Tax in the tax year. A declaration can be made in writing, online or by voice. If it is made by voice, it does not take effect until the charity has sent the donor a written record of it, so the system has to know when that record was sent.

That short list has consequences for a system:

  • “Full name” means one person. HMRC’s detailed guidance rules out joint names and company names, so “The Khan family” or “Anonymous” cannot carry a claim.
  • “Home address” means home. A work address or an email address is not enough, and a UK donor record with no postcode will stop a claim.
  • “Which donations” matters. A declaration can cover one gift, or all gifts from a stated date onwards, including earlier ones within HMRC’s time limits. Your system has to know which, because that decides which donations are eligible.

The seven things to keep, together

  1. The declaration itself, in the form it was given: the scanned paper, or for an online declaration the exact wording the donor saw and the date and time they agreed to it.
  2. The donor’s full name and home address at the time, and a history of changes. If a donor moves or changes their name, record the change and the date, and keep the old details.
  3. What the declaration covers: this gift only, or past and future gifts, and from what date.
  4. Each donation: date, amount, how it was paid, and which donor and declaration it belongs to.
  5. Anything that makes a donation ineligible: HMRC’s list of what you can claim it on excludes, among others, payments for goods or services, donations where the donor gets a benefit above HMRC’s limit, and donations from limited companies.
  6. Withdrawals and changes: the date a donor cancelled their declaration or told you they no longer pay enough tax. Donations after that date must not be claimed.
  7. What was claimed: which donations went into which claim, on what date, so that nothing is claimed twice and a refund can be traced back to its claim.

The word that matters is “together”. Most charities hold all seven somewhere. The trouble starts when the declaration is in a filing cabinet, the donation is on a bank statement, the address is in a mailing list and the claim is in last year’s spreadsheet.

HMRC’s page on declarations says to keep a record of each declaration for 6 years after the most recent donation you claimed Gift Aid on. Its detailed guidance adds rules for the other records that depend on whether your charity is a company or a trust. Check the rule that applies to you with your accountant, write it into your retention policy, and make sure your system does not delete declarations sooner.

Where spreadsheets go wrong

A spreadsheet can run Gift Aid for a small charity, and many do. It starts to fail in predictable places:

  • One donor, three spellings. Duplicates split a donor’s giving across rows, and one of them has no declaration attached.
  • Overwritten addresses. Someone updates an address and the old one, the one on the declaration, is gone.
  • No link between gift and declaration. A column says “GA: Y”, but nobody can produce the declaration that justifies it.
  • Regular gifts that changed. A standing order was cancelled or the donor withdrew their declaration, and the row still says yes.
  • Claimed twice, or never. With no record of which rows went into which claim, the safe choice is to under-claim, and that is money the charity was entitled to.
  • Everyone can see everything. Home addresses and giving history for every donor, open to anyone with the file.

If two or more of these sound familiar, the spreadsheet has become a system without the safeguards of one.

Questions to ask of any donation platform or system

Whether you are choosing a giving platform or having something built, ask to be shown, not told:

  1. Where is the declaration wording stored, and can I see the exact text a donor agreed to two years ago?
  2. What happens to the old address when a donor moves?
  3. Can I mark a single donation as not eligible, with a reason?
  4. When a donor withdraws, do later gifts stop being claimed automatically?
  5. Can it produce the list for a claim in the layout HMRC asks for, and does it mark those donations as claimed?
  6. Who can see donor addresses and giving history, and is that controlled by role?
  7. Can I export everything, declarations included, if we leave?

A giving platform that does all of this is the right answer for most small charities, and cheaper than anything built for you. Bespoke makes sense when donations are one part of a larger picture: memberships, events, sponsorships or pledges that have to be reconciled with them, or when the platform’s fees on your volume cost more each year than a system of your own.

What we would build, and what we would not

When we build a donation system or a donor area, the seven records above are part of the design from the first day: declarations stored with their wording and time, address history kept, each gift tied to its declaration, and claims recorded so nothing is counted twice. Staff see only what their role needs. We do not give tax advice, and we will ask your treasurer or accountant to confirm the rules the system enforces before it goes live.

If the real problem is the hours spent each quarter assembling a claim from four places, an Automation Audit (£750) is the place to start: in five working days we map the steps and recommend what to automate first, with a price for it. If donations, members and events all need one home, see our portal packages, from £9,500.

Prices in this guide do not include VAT. Tibyan Labs is not registered for VAT, so none is added at present.

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Related: When should a spreadsheet become a system?