Beyond the List: How Should Charities Account for Trust? What Section 88 Brings to the Surface

On 8 July 2026, the Government replied to a Legislative Council question on the regulation of charitable organisations. The reply listed the total number of Section 88 tax-exempt charitable organisations, new approvals and withdrawals from 2021/22 to 2025/26. It also explained that public-fundraising activities are regulated by different departments according to their respective powers, while the Government continues to examine proposals for a dedicated charity regulator (HKSAR Government, 2026).

The value of this reply is not only whether the list has grown or shrunk. It brings a more dispersed question back into public view: after a charity has obtained Section 88 status, how can the public tell whether it is trustworthy?

Lingxi Insight sees Section 88 as an institutional entry point. Organisations need to see trust in everyday work before they can explain it to the public.

This is why the topic should not become a legal explainer. Section 88 is the recent signal. The deeper question is how an institutional status becomes something donors, service users, volunteers and partners can understand, question and check in ordinary organisational work.

What does the public encounter first?

Most people do not read a full governance document before deciding whether to support an NGO. They may first meet a volunteer at a street station, complete an online donation form, receive a monthly-giving confirmation email or walk into a service centre and ask: "Where will this money go?"

These are small contact points, but they are where trust begins to take shape. A clear receipt, an explanation of fundraising use, a named response to an enquiry and a follow-up after a referral all influence whether people feel that an organisation is accountable.

For frontline staff, the issue is not necessarily memorising every regulation. It is being able to give a consistent, non-evasive answer in different situations. For management, the question is whether those answers return to finance, services and risk management, instead of depending on one colleague's memory.

Annual reports are not the end of the conversation

Annual and financial reports are often treated as yearly administration. They are also public interfaces through which an organisation explains itself to different stakeholders. The Community Chest of Hong Kong's 2024/25 annual-report page brings together annual-report, financial and allocation materials. The Hong Kong Sheng Kung Hui Welfare Council's publications page also makes annual and financial reports publicly available. These pages do not prove that public trust has increased. They do, however, give readers a route to ask how resources relate to services, how responsibility is presented and whether the organisation's account can be compared over time (The Community Chest of Hong Kong, 2025; Hong Kong Sheng Kung Hui Welfare Council, 2025).

The Social Welfare Department also maintains a public page for annual financial reports from non-governmental organisations. Publishing a document is not the same as completing accountability. Organisations also need to consider whether a reader can answer the following three practical questions.

The point of a public report is not to make every page longer. It is to give an external reader a reasonable path from numbers and descriptions to organisational responsibility.

Large, medium and small organisations face different complexity

Trust management should not become a ranking by size. A large organisation may have multiple service centres, fundraising channels, brand partnerships and cross-departmental data. It therefore has more complicated questions about access, money flows, handovers and board reporting. A medium-sized or smaller organisation may be closer to one community, but it still needs to manage receipts, fundraising use, financial disclosure, volunteer authorisation and frontline enquiries. CW CPA (2026) similarly notes that NGO boards in Hong Kong need to bring financial oversight, risk management, compliance and stakeholder responsibilities into one governance view.

Different scale can justify different management models. It does not remove responsibility. The useful question is not which type of organisation is naturally more trustworthy, but whether it connects several important points:

• Before fundraising, does it explain the purpose, restrictions on use and enquiry route?
• During service delivery, do frontline staff and service centres know how to record needs, referrals and responses?
• In finance, can management see concentration of funding, administration costs, incomplete commitments or unusual spending?
• At board level, are conflicts of interest, complaints, data risks and major service risks reviewed?
• In the annual account, can finance, services and limitations be explained in a context that a reader can follow?

These questions do not require every organisation to use the same template. They require each organisation to know where trust must be seen in everyday work, and where the connection can break.

Lingxi Insight: Put trust back into everyday management

The Section 88 discussion eventually returns to an ordinary situation: when a donor, service user, volunteer or partner asks a question, can the organisation find the right information within a reasonable time, identify who is responsible and explain the next step?

Trust cannot be reduced to a CRM, and purchasing a system cannot replace board judgement. Tools can help an organisation organise donor and member records, service-centre responses, fundraising and programme data, board reports and audit trails. The real responsibility remains with the organisation: defining standards, assigning access, handling exceptions and acknowledging limitations in public.

An organisation can begin with a small check. Take one fundraising activity, one service referral and one financial figure. Can each be traced from a frontline record to a management judgement, and then explained to a donor through public information? If every answer requires finding a particular colleague, searching multiple spreadsheets or reconstructing a conversation, the problem may not be that the public is unwilling to trust the organisation. The organisation may not yet be managing the forms of explanation that trust requires.

The Section 88 list can tell us which organisations have entered a discussion about institutional status. Trust is built beyond the list, through everyday work that explains, responds and improves.