The Apostolic Project
PHASE 5 — UK CHARITY & LEGALITY
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Purpose
“To advance the Christian faith through worship, teaching, discipleship, community support, and the demonstration of the ministry of Jesus Christ in healing, deliverance, and spiritual formation.”
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Safeguarding Policy (Children & Adults at Risk)
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Trustee Eligibility & Automatic Disqualification Rules
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Safer Recruitment & Enhanced DBS Requirements
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Equality Act 2010 — Religious Occupational Requirements

Phase Vision & Foundation
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🔥VISION
To establish Kerygma Apostolic Ministry / Kerygma Church as a legally recognized UK charity that:
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Is fully compliant with Charity Commission and UK law
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Protects children and vulnerable adults with robust safeguarding standards
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Upholds New Testament holiness and leadership standards for anyone in ministry, employment, or governance
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Is structurally strong enough to support church, schools, missions, inner healing and deliverance for decades.
This phase is about building a legal framework that cannot be easily shaken by cultural pressures, while staying within the law and keeping a clear biblical conscience.
📖BIBLICAL FOUNDATION
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1 Timothy 3:1–13; Titus 1:5–9 – Moral qualifications of elders and deacons: faithful in marriage, self-controlled, not greedy, above reproach, good reputation with outsiders.
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1 Peter 2:12 – “Keep your conduct among the Gentiles honourable…” – integrity before the watching world.
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Romans 13:1–4 – Submission to governing authorities as servants of God for order and justice.
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1 Corinthians 5:1–13 – Clear church discipline regarding sexual immorality and public sin.
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Acts 6:1–6 – Selection of leaders with good reputation, full of the Spirit and wisdom.
These passages justify:
High internal standards for leaders and workers. Clear separation from ongoing sexual immorality and scandal and seriousness about reputation and safeguarding inside and outside the church.
🎯OBJECTIVES
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Register Kerygma as a UK charity (likely “advancement of religion” as main charitable purpose).
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Create legally compliant policies for:
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Safeguarding children and adults at risk
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Safer recruitment and DBS checks
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Complaints and whistleblowing
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Data protection and governance.
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Develop an internal Code of Conduct that sets out NT standards on:
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Sexual behaviour (adultery, fornication, pornography, same-sex practice, abuse)
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Integrity (financial honesty, abuse of power, manipulation, spiritual abuse)
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Confidentiality and pastoral care.
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Define clear disqualification criteria for trustees, staff and ministry leaders, aligned with:
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Automatic disqualification rules for trustees and senior managers
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DBS and safeguarding guidance
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Ensure full safeguarding compliance for all children’s and youth work.
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Build a governance structure (trustees, constitution, minutes, risk register) that can withstand scrutiny from:
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Charity Commission
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Local authorities
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Insurance and safeguarding bodies.
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Align policies with the Equality Act 2010, using the legitimate religious/charity exemptions where appropriate and lawful, while avoiding illegal discrimination.
🤝REQUIREMENTS
A. LEGAL & GOVERNANCE
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Charitable purpose clearly stated (e.g. “Advancement of the Christian faith…”).
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Governing document (constitution / trust deed / CIO constitution) setting out:
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Objects
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Trustee roles
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Membership
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Decision-making and discipline.
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Trustee body – minimum 3 (better 5+), none automatically disqualified.
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Risk register including:
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Safeguarding
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Financial controls
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Reputational risk
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Legal risk around employment and equality law.
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B. SAFEGUARDING (CHILDREN & ADULTS AT RISK)
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A written safeguarding policy compliant with Charity Commission guidance, covering:
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Children (under 18)
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Adults at risk
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A Designated Safeguarding Lead (DSL) and deputy.
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Safer recruitment procedures: references, interviews, DBS checks.
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Clear reporting and escalation procedures for allegations and concerns, following Charity Commission and statutory guidance.
C. CRIMINAL RECORDS & TRUSTEE ELIGIBILITY
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Follow automatic disqualification rules for trustees and certain senior manager roles. Certain offences (e.g. dishonesty, terrorism, money laundering, some sexual offences) lead to automatic disqualification unless a waiver is granted.
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People on the sex offenders register are disqualified from trusteeship and senior positions.
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For staff and non-trustee volunteers, use:
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DBS checks
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Written risk assessments
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Role-by-role decisions, particularly for anyone with past convictions related to abuse, violence or exploitation.
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Your instinct (“no-one under police surveillance or with court record in key positions”) needs to be translated into something that respects the Rehabilitation of Offenders Act and Charity Commission guidance: you can be very strict for trustees, senior staff and all children’s / vulnerable adults roles, but you must be proportionate, documented, and non-discriminatory in law.
D. EQUALITY & INTERNAL CODE OF CONDUCT
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UK law protects characteristics like sex, sexual orientation, religion/belief under the Equality Act 2010.
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Charities and religious organisations have some specific exemptions that allow them to:
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Restrict certain benefits or roles to those who share the faith or certain characteristics if this is in their governing document and objectively justified, or to correct a disadvantage.
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In some employment situations, define a genuine occupational requirement that a role be filled by someone living in accordance with the organisation’s beliefs (this must be framed carefully and legally).
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However, you cannot simply ignore the Equality Act; and if you deliver services under contract for a public authority, you normally cannot discriminate on sexual orientation in providing those services. So:
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You can create an internal Biblical Lifestyle & Leadership Standard for leaders, workers and teachers, including sexual ethics, but the wording must be legally reviewed so it:
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Focuses on behaviours, not hatred of groups
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Applies consistently
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Uses permissible religious exemptions and occupational requirements.
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🛠️KEY ACTIONS
5.1. CHARITY STRUCTURE & REGISTRATION
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Clarify legal form: e.g. Charitable Incorporated Organization (CIO) – typical for churches.
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Draft a governing document (constitution) including:
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Objects (advancement of the Christian faith etc.)
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Doctrinal basis
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Membership, discipline, leadership.
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Identify initial trustees and check:
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Automatic disqualification
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Eligibility and conflict of interest.
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Prepare and submit Charity Commission application with:
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Governing document
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Activities description
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Public benefit statement
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Financial projections.
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5.2. SAFEGUARDING & CHILD POLICY
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Draft a Child Safeguarding Policy (you can adapt a church template such as URC, CofE or NSPCC-linked models).
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Draft an Adults at Risk Safeguarding Policy (can be combined or separate).
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Appoint a Safeguarding Lead and deputy; provide them with formal training (NSPCC / local authority / Christian safeguarding training).
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Implement safer recruitment:
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Role descriptions
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Application forms
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Two references
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Enhanced DBS where needed
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Written agreements for volunteers.
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5.3. INTERNAL POLICY & HOLINESS
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Draft a Leadership & Worker Code of Conduct, including:
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Sexual ethics (adultery, fornication, exploitation, abuse, coercion, pornography)
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Boundaries in pastoral relationships
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Social media and online conduct
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Financial integrity and conflict of interest.
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Include clear discipline and removal procedures for leaders / staff who:
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Persist in serious sin
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Breach safeguarding
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Bring the charity into disrepute.
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Obtain legal review of:
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Code of Conduct
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Recruitment criteria for staff and volunteers
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Any faith-based behaviour expectations linked to employment and leadership.
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5.4. CRIMINAL RECORDS & HIGH-RISK CASES
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Implement a policy on recruiting people with criminal records, aligned with:
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Automatic disqualification (trustees / senior managers)
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DBS guidance and risk assessments for any work with children or adults at risk.
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Explicitly prohibit:
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Anyone on the sex offenders register from any leadership, trustee, or children/vulnerable-adult-facing role.
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5.5. TRAINING & CULTURE
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Run annual safeguarding training for:
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Trustees
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Staff
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Volunteers.
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Develop a Culture of Reporting:
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Clear route for raising concerns
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Whistleblowing protection
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Commitment to report serious incidents to the Charity Commission where required.
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⏳TIMELINE
Start target: January 2027
Estimated duration: 9–18 months (depends on speed of drafting, trustees,
and Charity Commission response).
Jan–March 2027
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Confirm legal structure (CIO etc.)
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Draft governing document & doctrinal basis
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Identify trustees; check eligibility and conflicts
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Start drafting safeguarding & conduct policies.
April–June 2027
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Finalize:
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Safeguarding policies
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Code of Conduct
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Criminal records / DBS policy.
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Begin safeguarding training for trustees and key volunteers.
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Prepare financial projections and activity descriptions.
July–December 2027
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Submit Charity Commission registration.
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Respond to any questions or clarifications from the Commission.
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Fully implement:
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Safeguarding procedures
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Reporting lines
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Safer recruitment.
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Realistically, safeguarding and governance must be working even before registration is approved – the Commission is increasingly strict about this.
✔️EXPECTED OUTCOMES
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Kerygma Church / Kerygma Apostolic Ministry registered as a UK charity, with clear charitable purposes and public benefit.
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A trusted legal framework: constitution, trustees, policies and procedures that satisfy Charity Commission expectations.
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Robust safeguarding culture, with:
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Child and adult policies
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Named safeguarding leads
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Regular training and DBS checks.
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A Biblical Lifestyle & Leadership Standard in force, making it crystal-clear who can and cannot lead, teach, or represent the ministry.
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Clear processes for dealing with sin, abuse, and serious misconduct – protecting the flock and the name of Christ.
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A structure that:
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Honours New Testament standards,
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Obeys UK law, and
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Is resilient against future cultural and legal pressure.
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A legal platform ready for Phase 6 – Apostolic Centre / property and expansion, with credibility before banks, donors, authorities and the wider church.
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