Why this memorandum?

The success of a fundraising campaign is not complete without the management of its proceeds with precise regulatory compliance and disciplined financial disclosure. The aim here is to regulate what happens after fundraising: the required reports, expenditure controls, and accounting records, based on the current laws and regulations in the Kingdom.

First: Required Reports After the Campaign

1) Donation Collection Report (within 30 days of license expiration)

The licensee must provide the center with a report on donation collection within thirty (30) days from the date of license expiration, or every six months if the license duration exceeds six months. The report must include at least:

  • A bank statement dedicated to the collection.
  • A record of donations for each transaction (source, channel, cash donation value or estimated value of in-kind donation, date).
  • Receipts of acknowledgment/collection.

2) Donation Expenditure Report (within 30 days of the expenditure plan conclusion)

If there was an approved expenditure plan for the campaign, an expenditure report must be submitted within thirty (30) days from the date of the expenditure plan conclusion, or every six months if the plan extended for more than six months.

Professional Note: Some commonly circulated formats refer to a “15-day” deadline. According to the current executive instructions applicable to fundraising activity, the deadline is “30 days” as stated earlier, with a semi-annual periodicity for longer campaigns or expenditure plans.

3) Semi-Annual Financial Report for Surplus/Long-Term Projects

In case of surplus funds or programs whose execution exceeds one year, the center should be provided with a semi-annual financial report detailing the areas of expenditure and the surplus amounts.

4) Annual Final Account

The association is obliged to provide the center with the annual final account within four months from the end of its financial year, utilizing an external auditor licensed in the Kingdom.

Lawyer's Advice: Start preparing draft reports from the first day of the campaign via a tracking dashboard linked to the dedicated bank account; this reduces the risks of delays or lack of supporting documents.

Second: Governance of Expenditure and Internal Control

1) Principle of Separation and Balance of Authorities

The governing framework emphasizes that no individual may hold absolute power in decision-making, and calls for organizing the decision-making process and distributing tasks and responsibilities during it. This is the legal basis for adopting dual signature controls and a written authority matrix.

2) Responsibilities of the Board of Directors and Delegation of Powers

The Board of Directors is responsible for the association's funds and assets, and must determine the powers it delegates and the decision-making procedures and duration of delegation, and monitor their practice through periodic reports. They must also establish procedures to inform new members of the relevant financial and legal aspects.

3) Role of the Executive Body and Oversight

The executive body applies the internal control systems and regulations and risk management, and prepares periodic financial and non-financial reports presented to the Board of Directors or the General Assembly as appropriate.

Recommended Best Practice:

  • Dual signatures for the disbursement of any amount from the campaign account (e.g., Executive Director + Financial Director).
  • Authority matrix defining the spending limits for each position/committee, with expiration dates for the delegation and review mechanism.
  • Monthly bank reconciliation between the bank statement and the donation record and receipts of acknowledgment/collection.

Legal Note: The cited documents do not contain an explicit text that requires a specific number of “signatures” for expenditure, but governance rules and internal control mandate strongly advocate for the adoption of “dual signatures” to prevent concentration of power and mitigate the risks of errors or misuse.

Third: Accounting Records (Donation Register)

The regulations require the association to create and update a donation register, including—at a minimum—the donor's information and contact details, the donation value (cash/in-kind), donor conditions (if any), and the donation channel; taking into account the donor's conditions when handling the funds.

Executive Procedure: Link the register to the fundraising platform and the bank account to generate a unified transaction number mentioned in: (donation register, bank statement, receipt, and disbursement voucher), to facilitate tracking and matching during report preparation.

Fourth: Management of In-Kind Donations and Cross-Border Transfers

  • In-kind donations: are not accepted outside of the headquarters without the center's and relevant authorities' approval; estimated values should be considered when necessary, reflecting in the financial statements according to regulations issued by the CEO.
  • Deposits and transfers from outside the Kingdom: are only accepted after the board/center's and relevant authorities' approval.

Fifth: Management of Surplus and Redirecting Donations

  • Surplus or unspent amounts are processed according to the guidelines: spending them on the same purpose (if possible) or—after the center’s approval— depositing them in its account or directing them to charitable purposes as deemed appropriate. Redirecting donation amounts to another project requires the donor's approval.

Conclusive Summary

Compliance is not an operational burden but a legal safeguard and professional reputation: a timely report, a documented receipt, and disciplined expenditure with clear authorities—all of which build trust with donors and supervisory entities, fortifying the association against risks and accelerating the flow of resources in the future.

Referenced Regulations

  • The executive instructions for the donation collection regulation: reports (30 days/semi-annual), report contents, handling surpluses, in-kind donations, and external transfers.
  • The executive regulation for the Associations and Private Institutions Law (2025): donation register and its components; final account within 4 months; Board of Directors' responsibilities and delegated powers.
  • Governance rules for associations and private institutions: non-concentration of decision-making authority, organizing the decision-making mechanism, internal control, risk management, and periodic reports.

Final Practical Note: It is advisable to adopt a written “Post-Fundraising Policy” integrated into the internal control system, linking: (a) the campaign bank account, (b) the donation register, (c) the authority matrix, (d) the schedule of mandatory reports—with a designated compliance owner and performance indicators for timely and documented compliance.