What Can an NGO's Website Answer Before FCDO Due Diligence Starts?
Key takeaways
- FCDO's due-diligence and central assurance assessments look at five pillars: governance and internal controls, ability to deliver, financial stability, downstream delivery and safeguarding.
- Nothing in FCDO's guidance requires a partner to publish a due-diligence pack; a public one is a convenience that shortens the conversation, not a condition of funding.
- FCDO's counter-fraud standards for external partners set out what it expects on controls and downstream due diligence, and say of themselves that using the document is not mandatory.
- Two website duties do come from the funding agreement: FCDO's branding guidance lists websites as a place to acknowledge UK funding, and FCDO mandates IATI publishing in most of its agreements.
- Bank details, full insurance schedules and a delivery chain map that names partners in insecure places belong in a pack sent on request, never on a public page.
- Every document on the page needs a named owner, the date it was approved and the event that triggers its next review, or the pack answers one question and raises the next.
Summary
FCDO assesses the partners it funds against five pillars: governance and internal controls, ability to deliver, financial stability, downstream delivery and safeguarding. A website can answer most of the public half of that before anyone asks: registration, trustees, accounts, programme evidence, how you work with partners and the policies behind each pillar. Bank details, full insurance schedules and anything that could put a partner at risk belong in a pack you send on request. Nothing in FCDO's guidance requires a public due-diligence pack, so this post sets out what is worth publishing, what is not and who owns each document's review date.
The Short Answer
Most of it. Your website can show the public half of all five pillars FCDO assesses: who governs you, what you have delivered, your accounts, how you choose and check partners, and your safeguarding and fraud policies. Bank details, full insurance schedules and anything that could expose a partner belong in a pack you send on request. Nothing in FCDO's guidance requires a public pack. What a published one does is let the assessor start from your documents instead of from a list of questions.
A due-diligence request rarely stalls for want of a document. It stalls on a document nobody can date.
What FCDO Assesses
FCDO's SEAH due-diligence guidance for implementing partners, updated on 30 June 2026, names the frame in one sentence: its due-diligence and central assurance assessments look at five pillars. They are governance and internal controls, ability to deliver, financial stability, downstream delivery and safeguarding. The guidance then explains only the fifth, in six areas, and applies to organisations receiving funds through an Accountable Grant or a Memorandum of Understanding.
It says nothing about websites. No pillar is met by publishing, and no part of the guidance asks for a public pack. The case for one is practical: the same documents are requested by every institutional funder, and by you of your own downstream partners. The NGO website section checklist carries the pack as a Best practice row for that reason.
UK trusts and foundations run a different, lighter check, covered in what grant funders check on a charity website. What the law requires every charity to show is in Charity Commission website requirements. This post assumes both and deals with the FCDO frame.
Pillar by Pillar
| Pillar | What the website can answer | What goes in the pack on request | Who owns the review date |
|---|---|---|---|
| Governance and internal controls | Trustees and roles, governing document, code of conduct, conflicts of interest policy, fraud and anti-diversion statement | Board minutes, the risk register, the internal controls framework | Governance lead; trustees approve the policies |
| Ability to deliver | Programme pages, where you work, evaluations, IATI data where your agreement requires it | Detailed workplans, staffing, the MEL framework | Programmes or MEL lead |
| Financial stability | Annual report and accounts, who audited or examined them, the types of insurance cover held | Bank details, management accounts, full insurance schedules | Finance lead |
| Downstream delivery | How you choose and check partners, what you expect of them, your safeguarding standards for partners | The delivery chain map, partner due-diligence records | Partnerships lead |
| Safeguarding | Safeguarding policy, code of conduct, a route for reporting a concern, the safeguarding lead by role | Case logs, investigation procedure, training records | Safeguarding lead, with the board-level officer |
Governance and internal controls. This is the pillar a website serves best, because most of it is already public in some form. FCDO's counter-fraud standards for external partners set out the minimum it expects partners to show on managing aid diversion, including a code of conduct that staff and downstream partners understand. Read their status carefully. They say "should" throughout, they say "Using this document is not mandatory", and they are published as a PDF on the Prevent Charity Fraud site rather than on GOV.UK. They describe what an assessor will ask about, not a publishing duty.
Ability to deliver. Programme pages and evaluations are the evidence here, and a results page that includes what did not work reads as more credible than one that only reports success. Where your agreement carries the IATI clause, your published data is part of the answer; the next section covers it.
Financial stability. The accounts and the annual report, dated on the page, with a line on whether they were audited or independently examined. Bank details never go on a public page. They are what a payment-diversion fraud needs, and an assessor who needs them will ask. I would list the types of insurance cover held on the public page and keep the schedules and limits in the pack.
Downstream delivery. The counter-fraud standards expect partners to complete due-diligence checks on each downstream partner and to keep a delivery chain map up to date. The SEAH guidance makes first-tier partners responsible for cascading its standards down the chain. The website can say how you do this: your partnership principles, what you ask of partners and the safeguarding standards you share with them. The map itself stays in the pack. It names organisations, sometimes in places where being linked to UK funding is a risk. The partner-facing side of this, and which partners to leave unnamed, is in what local partners look for.
Safeguarding. The SEAH guidance expects a designated safeguarding officer at board level, a code of conduct and a way for "beneficiaries and other stakeholders outside of the organisation" to complain and raise concerns. That last expectation is the one that needs a public route. How to build complaints and concerns routes as one structure is covered in complaints and speak-up pages. Name the safeguarding lead by role, with a role mailbox, so the page survives a change of staff. What the safeguarding page itself should let people do is in what a safeguarding page should let people do.
Two Pages That Come From the Agreement
Two website duties are real, and both arise from the funding agreement rather than from statute.
Acknowledging the funding. FCDO's branding guidance for ODA-funded programmes makes branding a condition of accepting funding for implementing partners. It lists websites, on the home page or a page listing donors, among the places to acknowledge it. The main mark has been UK International Development since the brand launched in April 2023. The guidance also allows exceptions where showing UK support would endanger the people a programme serves or its staff. How to govern funder logos, including taking them down when a grant ends, is in logo walls as governance.
Publishing to IATI. FCDO's IATI guidelines say it "encourages, and in most agreements mandates" implementing partners to publish organisation and activity data to the IATI Standard, with activity data updated at least quarterly. The publishing happens through IATI's own systems, not on your site, and the IATI Registry was replaced in December 2025, so check any old links. The page on your site is what an assessor actually clicks: your organisation identifier, a link to the data and how often it is refreshed. Check your own agreement for the deadline; the guidelines do not set one.
Christian Aid's accountability and transparency hub shows the shape of a page like this. Annual reports, safeguarding, an anti-diversion and abuse policy, codes of conduct, a link to its IATI data and its complaints routes sit on one page. I loaded it on 30 September 2026. It is a public example of the pattern, not a template for your own documents.
Sanctions and Counter-Terrorism
Sanctions and counter-terrorism law apply to your organisation whether or not FCDO funds you. The Charity Commission's guidance on charities and terrorism sets out the legal framework and the lists trustees need to know about. How you screen is a matter for your trustees and your adviser, not your website.
What the page can carry is short: a zero-tolerance statement, a sentence saying that you screen partners and suppliers, and a confidential route for reporting suspected fraud, bribery or diversion. The screening procedure and its records go in the pack.
Public or On Request
The line between the two is not about how sensitive a document feels. It is about what harm the document could do in the wrong hands, and to whom.
Publish what describes you: who you are, how you are governed, what you have delivered, what you spent and the policies you hold yourself to. Send on request what could be used against you or against someone else:
- Bank details, which are what a payment-diversion fraud needs.
- Full insurance schedules, which carry limits, policy numbers and insurer details that nobody outside the agreement needs.
- Management accounts, which are unaudited and go out of date quickly.
- The delivery chain map, and any document that names partners or staff where the association carries risk.
The public page should still say that each of these exists and how to request it. A pack sent on request must carry the same dates as the public versions. If it does not, the reader holds two versions of your organisation and has to decide which one is true.
Who Owns Each Review Date
A due-diligence page collects documents from four or five teams, which is why it goes stale faster than any other page on the site. The fix is not a stricter editor. It is a date on every document and a named owner behind each one.
For each document, the page needs the date it was last approved, the role that owns it and the event that triggers its next review. Most triggers are predictable: new accounts filed, a policy re-approved by the board, a new FCDO agreement signed, a change of safeguarding lead. Write those triggers into your website governance policy, and put the page itself on the review cycle described in content governance for nonprofit websites.
I would show the approval date beside each document on the page, not only inside the PDF. An assessor reads the dates before the documents. A current date tells them the policy is live. A missing one tells them to ask.
A public pack will not pass due diligence for you, and FCDO does not ask you to publish one. What it does is answer the first round of questions before they are sent, so the conversation starts with your evidence. The documents answer the question. The dates answer the next one.
Further Reading
- NGO Website Section Checklist: row 13, Due-diligence summary
- NGO Website Section Checklist: row 15, Funder acknowledgement
- NGO Website Section Checklist: row 16, Transparency and IATI
- NGO Website Section Checklist: row 48, Due-diligence document pack
- NGO Website Section Checklist: row 50, Fraud, bribery and sanctions
- What Grant Funders Check on a Charity Website Before Awarding a Grant
- Charity Commission Website Requirements: What UK Charities Must Publish
- Content Governance for Nonprofit Websites
- What Should a Charity's Safeguarding Page Let People Do?
- What Do Local Partners Look For on an International NGO's Website?
What This Post Does Not Cover
This is about the website: what it can publish, what it should hold back and who keeps it current. It is not advice on how FCDO scores an assessment, on meeting its standards or on sanctions and counter-terrorism compliance, which belong with your trustees and your own legal adviser. It does not cover the terms of any particular funding agreement; where this post and your agreement differ, the agreement governs.
Two clicks. Three things.
Send the address of your website. Within two working days you get a short email naming the three things a funder would hold against it, including what AI assistants like ChatGPT and Google’s AI Overviews currently say about you. No report, no call, no follow-up unless you ask.
Received. Your three things arrive within two working days.
That did not send. Email hello@socialectric.com with your website address and I will reply from there.
Frequently asked questions
- Does FCDO require us to publish our policies on our website?
No. The SEAH due-diligence guidance sets out what FCDO assesses, and nothing in it requires a partner to publish a due-diligence pack. It does expect people outside the organisation to be able to raise concerns, which in practice means a findable route. The two duties that do reach the website, branding and IATI, come from the funding agreement. The section checklist tags the pack Best practice for that reason.
- What should we send on request rather than publish?
Bank details, full insurance schedules, management accounts, the delivery chain map and anything that identifies partners or staff in places where being linked to UK funding could put them at risk. The public page can say that each of these exists and how to ask for it. The pack you send must carry the same dates as the public versions, or the two will disagree in front of the reader.
- Do we need a separate page for FCDO, or does a general funders page do?
One page organised by the five pillars answers most institutional funders at once, because the documents they ask for overlap heavily. UK trusts and foundations check some different things, set out in what grant funders check on a charity website. A single page with both sets of documents, each dated, is easier to keep current than two.
- Should our sanctions screening process be on the website?
A short statement that you screen, and a confidential route for reporting suspected fraud or diversion, can be. The process itself belongs in the pack and with your adviser. Sanctions and counter-terrorism law apply to you whether or not FCDO funds you; the Charity Commission's guidance on charities and terrorism sets out the legal framework.
- Who should own the due-diligence page?
No single person can, because the documents come from finance, programmes, partnerships and safeguarding. Give the page an editor who keeps it together, and give every document on it a named owner, an approval date and a review trigger. The content governance post covers how to put pages like this on a review cycle.