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The New Coronavirus Regulations – An Initial Briefing for Charities and Faith Organisations

Third Sector and governance expert, Caroline Armitage looks at the new 'Rule of Six' and what this means for charities and faith organisations.

We have all heard a lot about the coming into force of the new “Rule of Six”. But what does it really mean? Many charities and faith organisations have been worried and concerned at how it may affect their activities. Over recent weeks they have worked hard to put in place Covid-secure practices and have been fearful they will all have to stop. Will they? Well the good news is: No, they won’t. These new regulations have been clearly targeted at social gatherings in private homes or elsewhere. So if you are a charity, church or other faith organisations you can still look at slowly and carefully opening up your activities.

Some law...

The new regulations (SI 2020 No 986 for those who want to know) have to be read with the existing (No 2) Regulations as already amended and it’s a pretty dense read. So here is a brief summary with some examples to help you try to get your head around it.

Gatherings are not restricted which

“Are reasonably necessary for work purposes or for the provision of voluntary or charitable services”.

The running of churches or other faith groups will fall into this and the government recognises that worship services fall within this construction. So do meetings of staff / volunteers for the purposes of running the charity, Trustees Meetings or AGMs or APCMs).

Meetings are also allowed for organised ‘support groups’. A ‘support group’ is a group to provide mutual aid, therapy or any other form of support to its members or those who attend its meetings. There is a specific list but it is not exclusive. Groups for the vulnerable, lonely or parent support groups would fall within this.

Gatherings of over 6 can take place on the organisation's premises or on other premises but not at a private dwelling either indoors or outdoors. Outdoor gathering must not be on public land, but can be on private land (with a few specific exceptions such as land which has been designated ‘right to roam’ land), so long as that private land isn’t a private dwelling.

And you as organiser must have carried out a full formal risk assessment and have taken all reasonable measures to limit the risk of transmission of the coronavirus, taking into account your risk assessment and any guidance issued by the government which is relevant to the gathering.

Things to remember

It is important to remember there may be multiple guidelines which need to be taken into account for instance:

  • If you are providing refreshments you should look at guidance for the hospitality industry
  • If you are using a multi-use community space you should follow the guidelines the organisation which runs it has put in place
  • If the meeting is including children and young people you should look at the relevant National Youth and Children’s Work Guidelines
  • If you are a faith body such as a church you should look to your relevant guidelines – so for instance churches would look to the Church of England Guidelines
  • Numbers attending such organised gatherings are restricted by the risk assessment which will include ensuring appropriate social distancing. The current government guidelines for social distancing are 2m or 1m+ (i.e. with other protective measures such as masks).

And of course some existing rules remain in place such as those restricting weddings and funerals to 30 people, and wearing face coverings in places of worship.

Here’s some examples

So, some examples of what you can and can’t do:

  • A nature conservation charity could hold guided walks or a conservation work day appropriately risk assessed and socially distanced
  • An outdoor worship service can be held again so long as relevant church and performing arts guidelines are followed and, as always, relevant social distancing is maintained
  • Meetings can be held in a vicarage but they must be limited to 6 people inside or outside – so you may be better off using your church hall!
  • You might struggle to open a mother and toddler group. For instance the Church of England Guidelines do not recommend activities for under 5s and it is likely to be very difficult to manage to maintain social distancing
  • A church or charity could hold a ‘coffee morning’ drop in providing mutual help and support, provided that if any refreshments were served the relevant hospitality guidelines are followed, or no refreshments provided, and of course social distancing is maintained.

If you are an organisation in the not-for profit-sector and would like further advice on this and other issues your organisation may be facing contact Caroline Armitage or Jonathan Masucci.

Girlings has offices in Ashford, Canterbury and Herne Bay.

Before relying on this commentary please read the Reliance on information posted section in our Terms of Website Use in our Legal section. Please note that specialist advice should be taken in relation to any specific queries and the information above is provided for general information purposes only.


Caroline Armitage

Consultant Solicitor
Corporate, Banking & Finance; Commercial Law


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Our Experts

Chris Brightling

Head of Department
Corporate, Banking & Finance; Commercial Law

Caroline Armitage

Consultant Solicitor
Corporate, Banking & Finance; Commercial Law

Jonathan Masucci

Corporate, Banking & Finance; Commercial Law

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