Every Destination Matters: a painted postal sorting alcove holds envelopes, parcels and cloth mailbags in separate compartments, a reflection on the care required when fundraising crosses state lines.
A practical guide to state registration, online appeals, professional fundraisers and donor receipts for US charities
By Arbab Naseebullah Kasi, Chief Executive Officer - CEO, Feel Worldwide Foundation Inc.
A nonprofit’s first fundraising campaign often begins with a modest plan: a donation page, a message to friends and an invitation to a local business. Then someone offers to share the appeal with colleagues in another state. The audience grows faster than the filing calendar.
That is the moment to ask a practical question: where, and in what way, is the organization requesting charitable support?
Federal tax exemption does not answer that question. Recognition under section 501(c)(3) does not automatically authorize fundraising throughout the United States. States have their own charitable solicitation laws, registration requirements and exemptions. The IRS itself directs charities to examine these separate obligations in its initial state registration guidance.
This article explains how to organize that review, with examples from Pennsylvania, Maryland, California and Connecticut. It is not a complete survey of every state or an assessment of any particular organization’s compliance. Official sources were checked on November 9, 2026. Laws, fees, forms and agency practices can change. Use the guide for general education and obtain qualified legal or tax advice for your actual campaign.
Start with the invitation rather than the first deposit
Registration obligations often arise before solicitation begins. Waiting until a campaign raises a large amount can therefore be too late. The activity that matters may be the request, even when no contribution follows.
Make a short inventory of planned appeals: direct mail, email, telephone calls, social posts, advertisements, events, grant requests and approaches to businesses. Note the intended audience and the states in which the organization has offices, employees, programs or property. The IRS cautions that state filing obligations can arise from several forms of activity, not just a charity’s place of incorporation. IRS periodic state reporting guidance.
For each relevant jurisdiction, locate the charity regulator, current instructions and any exemption procedure. The National Association of State Charity Officials directory is a useful route to official state contacts. Confirm the rules with the responsible agency rather than assuming the secretary of state handles every charity filing.
Keep incorporation, federal exemption, state tax treatment and charitable registration in separate records. A filing accepted in one system should not be presented as approval under another.
Treat exemptions as specific conditions to document
“We are small” is a reason to investigate an exemption, not a legal conclusion. Exemptions can depend on organizational type, receipts, fundraising methods or who is paid. Some require a notice or application, while others have different procedures. A change in activity can change the answer.
Pennsylvania illustrates why the measurement matters. Its published exemption list includes charities receiving $25,000 or less in gross national contributions annually, provided they do not compensate anyone who conducts solicitations. The word “national” matters: this is not simply a count of money received from Pennsylvania donors. Pennsylvania exclusions and exemptions.
The Department of State explains that a nonexempt organization soliciting Pennsylvania residents without current registration must file the required registration materials within 30 days of receiving more than $25,000 in gross national contributions, or before compensating someone to solicit Pennsylvania residents. Review the complete instructions and any separate obligations that remain after an exemption. Pennsylvania charity registration guidance.
Maryland shows that an exemption can still involve filing. Its current small-organization instructions require an Exempt Organization Fundraising Notice when an organization solicits in Maryland and received less than $25,000 in charitable contributions in its most recently completed fiscal year. That route cannot be used with a professional solicitor. The notice is due before solicitation and annually thereafter within eight months after the fiscal year ends. Maryland notice instructions.
California uses a different starting point. Organizations subject to its charity registration requirements generally must register within 30 days after first receiving charitable assets. Its guidance also addresses out-of-state charities doing business or holding charitable property in California, including active targeting of California residents for donations. As checked on November 9, 2026, the initial CT-1 registration fee is $50. Check applicability and exemptions rather than treating this as a universal rule for every nonprofit. California initial registration guidance.
These examples are not interchangeable. Record the applicable rule, the facts supporting your conclusion, the date checked and the event that would require another review. If an exemption depends on receipts or unpaid solicitation, someone needs to monitor both.
Evaluate online fundraising from the actual facts
A donation button does not produce the same answer in every state. Neither “the internet reaches everywhere” nor “we only fundraise online” is a sufficient compliance analysis.
The Charleston Principles are advisory guidelines approved by NASCO’s board in 2001, not a uniform national statute. They address factors such as the organization’s location, targeted solicitation, noninternet activity and repeated, ongoing or substantial online contributions from a state. Individual state law and implementation still matter. Do not treat the Principles as an automatic nationwide exemption.
Connecticut provides a particularly useful published example. Its Department of Consumer Protection says a Connecticut organization soliciting only through an online donation button needs to register there. For an out-of-state organization, a Connecticut resident independently finding its donation page does not, by itself, require registration under the agency’s described scenario. But contacting that resident for another donation, or otherwise soliciting a Connecticut resident, requires registration before doing so. The agency says it follows the Charleston Principles without having legislatively adopted them. Connecticut online solicitation guidance.
This distinction has an operational consequence. A donation from someone who independently found a website and a later email asking that person to give again are different facts. Review follow-up campaigns before uploading the donor list. Do the same before targeting advertisements geographically or asking an ambassador to approach a new audience.
Using a fundraising platform does not eliminate the charity’s need to understand its own obligations. California separately regulates charitable fundraising platforms and platform charities, with rules addressing registration, good standing, disclosures and donation handling. Its guidance also explains that a charity soliciting only for itself through its own platform is excluded from the special platform definition. That exclusion does not settle the charity’s ordinary registration duties. California platform guidance.
Ask the provider who legally receives the gift, who issues the acknowledgment, what fees apply, when funds move and what happens if the intended charity cannot receive them. Keep the answers with the campaign records.
Review paid help before signing a fundraising agreement
A contractor’s description of the service may not match the legal category. States can distinguish between someone who advises a charity, someone who solicits donations and a business that promises a charitable benefit from product sales.
California, for example, distinguishes fundraising counsel from commercial fundraisers. Its description of fundraising counsel excludes soliciting the public and receiving or controlling solicited funds. Commercial fundraisers can be paid to solicit on a charity’s behalf. The roles carry different requirements. California professional fundraiser guidance.
California’s commercial fundraiser rules include registration, a bond or cash deposit, campaign notice, reporting and written contract requirements. Charities cannot hire an unregistered commercial fundraiser where those requirements apply. California commercial fundraiser obligations.
Before engaging anyone, verify their current regulatory status in each relevant jurisdiction. Read the proposed agreement for fees, expense reimbursement, custody of donations, access to records, approval of appeals, cancellation terms and required state language. Assign a person inside the charity to review the campaign. Outsourcing the work does not make the organization’s interests self-protecting.
Cause marketing also deserves review. A business advertising that purchases will benefit a charity may be a commercial coventurer. California requires registration and reporting unless an applicable exemption is satisfied. California commercial coventurer guidance.
For a proposed sales campaign, define the amount or percentage going to charity, eligible products, dates and any maximum contribution. Avoid approving a vague promise such as “a portion helps our cause” before the parties have agreed what that means and checked the applicable rules.
Build renewals into the fundraising budget
Initial registration is only part of the work. A useful state record includes the registration number, current status, fiscal year-end, next deadline, extension procedure, fee basis, required financial statements and assigned owner. Store the submission and acceptance evidence together.
A federal return may support a state report without completing it. The IRS warns that states can require additional financial statements, schedules, accountant reports or answers, even when the federal return is complete. Federal filing thresholds do not necessarily control state reporting thresholds. IRS state reporting guidance.
California ordinarily requires annual renewal filings four months and 15 days after the fiscal year ends, subject to its extension rules and any applicable relief. The package includes Form RRF-1 with the relevant fee and either the specified Form 990 return or Form CT-TR-1, as applicable. Its instructions expressly exclude Schedule B from the filing. Read the current package requirements rather than uploading an entire tax folder. California annual renewal guidance.
Budget for the work as well as the filing fee. Depending on the jurisdiction and size of the organization, preparing the required financial information can involve professional costs. Do not spend every available fundraising dollar on promotion and leave no capacity for reporting.
If a registration is missing or delinquent, establish the facts promptly. Confirm the actual status, identify incomplete periods and ask the regulator or counsel what corrections and solicitation restrictions apply. A payment receipt alone is not evidence that a deficient filing has been accepted.
Separate donor acknowledgments from fundraising registration
Donor documentation is another responsibility. It concerns the gift and the donor’s tax substantiation, rather than whether an organization met a state’s solicitation requirements.
For a donor to claim a federal deduction for a single contribution of $250 or more, the donor generally needs a contemporaneous written acknowledgment from the charity. The deadline is the earlier of the date the donor files the original return for the contribution year or the return’s due date, including extensions. This is not a rule that every donor can safely wait until the organization’s preferred mailing date. IRS substantiation guidance.
The acknowledgment should identify the organization, state the cash amount and describe any noncash property without assigning it a value. It must state whether goods or services were provided in return. If they were, include a description and good-faith estimate of their value, or the required statement about solely intangible religious benefits when applicable. IRS written acknowledgment requirements.
For example, an acknowledgment for a hypothetical $300 cash gift with no benefit returned should clearly identify the charity and gift and state that no goods or services were provided. For donated equipment, describe the property rather than treating the charity as the donor’s appraiser. Record the gift date in the organization’s records and receipt process.
Separate contributions below $250 are not combined merely to test this acknowledgment threshold. Other recordkeeping requirements still apply to monetary gifts, and additional rules can apply to noncash property. Electronic acknowledgments can be used. IRS Publication 1771.
Check the full payment when benefits are provided
A quid pro quo contribution combines a gift with goods or services received in return. When the donor’s payment is more than $75, the charity generally must provide a written disclosure explaining that the deductible amount is limited to the excess over the benefit’s fair market value, with a good-faith estimate of that value. The disclosure belongs with the solicitation or receipt. Specific exceptions apply. IRS quid pro quo guidance.
Suppose a hypothetical supporter pays $120 for a fundraising dinner, and the meal and other benefits have a good-faith fair market value of $45. The potential charitable portion is $75: $120 minus $45. The disclosure requirement is tested against the $120 payment, not the $75 remainder. This calculation does not guarantee a deduction for a particular taxpayer.
Do not confuse the $250 acknowledgment threshold with the over-$75 disclosure threshold. A campaign can need the second statement even when a payment is below the first threshold. Before offering tickets, merchandise or membership benefits, have the valuation and receipt language reviewed. Check the current rules before relying on an exception for insubstantial benefits.
Read the state disclosure rules as well
A federal tax receipt is not necessarily the whole communication required by a state. Maryland’s published guidance, for example, requires conspicuous disclosure language on written solicitations and receipts. It addresses availability of the charity’s financial statement, contact details and access to records submitted to the Secretary of State. Maryland disclosure requirements.
Check the requirements applicable to the actual appeal, including its format and audience. Review campaign pages, email templates, event materials and automated receipts together. Use an accurate statement of registration status, never language suggesting that registration is a government endorsement of the charity or its results.
Use a campaign readiness checklist
Before the next appeal goes live, ask the responsible team to answer these questions in writing:
Where are we asking? Identify intended audiences, targeted states, planned channels and relevant organizational activity.
What supports our status? Retain current registrations or the documented basis and required filings for each applicable exemption.
What could change the answer? Watch contribution thresholds, paid solicitation, new locations and new audiences.
Who else is fundraising? Verify contractors, platforms and sales partners, with clear agreements and responsibility for donations and records.
What will donors receive? Check benefits, valuations, acknowledgments and state disclosure language before taking payments.
What happens after launch? Name the owner of receipts, reconciliation, regulator correspondence, renewals and campaign changes.
The point is to make the organization’s public invitation match its legal position and its capacity to follow through. A small charity can begin with a simple folder and a reliable calendar. What matters is that someone checks the rules, records the answer and revisits it when the facts change.
If you see a practical way to contribute to community-focused work, I warmly invite you to explore a partnership with Feel Worldwide Foundation. Share the contribution, location and outcome you have in mind so a possible fit can be considered. The invitation is to discuss collaboration, not a promise of legal advice, registration services or an approved partnership. If you would like to make a gift, please visit the Foundation’s donation page and review the available options and terms. Thank you for considering how you might take part.
