Nonprofit & Charity Policies

Adopting and Using These Templates

A policy template is a starting point, not a finished policy. Before adoption, each template should be:

1. Reconciled against your governing documents. Review your Articles of Incorporation, by-laws, and any trust deeds or donor restrictions. Policies must align with what your organization is legally permitted to do.
2. Tailored to your size and complexity. A five-person community centre may simplify certain sections; a multi-site organization with significant assets will need more detail on financial controls and delegation.
3. Adopted by board resolution. A board minute recording the vote to adopt a policy is your clearest evidence of governance intent. File it with your corporate records.
4. Assigned an owner and review date. Policies drift. Assign responsibility to a board member or staff lead, and schedule a formal review every two to three years or when material circumstances change (merger, new program, regulatory shift).
5. Communicated to staff and volunteers. A policy nobody knows about is a policy that won't be followed. Brief your team on the policies that affect their work.

Why Policies Matter for Canadian Charities and Nonprofits

Policies are where a board's obligations become operational. Letters patent, articles and by-laws establish what an organization may do; policies govern how it actually behaves. That distinction matters, because the Canada Revenue Agency, the courts, and funders assess conduct rather than intention. Directors of registered charities and non-profit corporations owe fiduciary duties and a duty of care, and both the Income Tax Act and corporate statutes such as the ONCA and CNCA impose obligations that ultimately rest with the board. A documented policy suite is the most reliable evidence that directors turned their minds to foreseeable risk before it materialized: that conflicts were identified and managed, that the organization maintained direction and control over its resources or applied the qualifying disbursement framework properly, that personal information was safeguarded under PIPEDA and Quebec's Law 25, and that staff and volunteers were given clear instruction. Where policies are absent, the CRA audit file tends to record an organization improvising; where they exist and are followed, the same file records a governance system functioning as intended. That difference frequently determines whether a compliance issue resolves through an education letter or escalates to a compliance agreement, sanctions, or revocation.

The practical risk, however, runs in both directions. An unadopted or ignored policy is worse than no policy at all, because it establishes a standard the board set for itself and then failed to meet — an unhelpful document to produce on audit, in litigation, or before an insurer. Templates are a starting point, not a deliverable. Each policy must be reconciled against the organization's by-laws and objects, adopted by board resolution recorded in the minutes, assigned to a named officer or committee for administration, distributed to everyone bound by it, and reviewed on a fixed cycle.

Implementation: Practical Steps

1. Conduct a gap analysis. Inventory what exists, and measure it against your by-laws, funding agreements, insurance conditions, and applicable statutes. Most organizations discover overlap and contradiction before they discover gaps.
2. Sequence by risk, not by ease. Address the areas that carry personal director liability or registration risk first — conflict of interest, financial controls and expenditures, direction and control over resources, privacy and breach response.
3. Customize before adopting. Align defined terms, approval thresholds, and reporting lines with your actual structure. A policy referencing a committee you don't have is a liability.
4. Adopt formally. Approve by board resolution, record it in the minutes, and maintain a policy register showing adoption dates, versions, and next review dates.
5. Assign ownership. Name the officer or committee accountable for each policy. Unowned policies go stale.
6. Distribute and confirm receipt. Circulate to directors, staff, contractors and volunteers, and obtain written acknowledgment — annually for conflict of interest declarations.
7. Review on a schedule. Annually at minimum, and immediately upon any legislative amendment, CRA guidance update, funding condition, or organizational change.
8. Document application. Retain the records the policy contemplates — declarations, incident reports, approvals. The policy proves the standard; the records prove compliance.

When to Bring in Counsel

These templates cover common ground. If your organization has any of the following, bring in experienced charity counsel before finalizing:

• Significant real estate holdings or complex leases
• Donor restrictions or legacy gifts with conditions attached
• Multi-jurisdictional operations or cross-border funding
• Substantial investment portfolios
• Prior CRA compliance issues or audit findings
• Concerns about director or officer liability

A policy review package with B.I.G. Charity Law Group typically includes a reconciliation of your templates against your governing documents, a risk assessment specific to your organization's size and sector, and a board-ready memo flagging gaps or conflicts. Reach out through the Book A Call button on our site to discuss your organization's needs.

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