This is general legal information, not legal advice. State laws differ and change, so confirm your situation with the state regulator or an attorney. Everything below was checked against regulator pages, statutes and NASCO documents in October 2026.
What is charitable solicitation registration?
It is a state filing that allows a charity to ask that state's residents for donations. It is separate from your IRS tax exemption and from incorporating. Where it applies, a charity typically registers with the attorney general, the secretary of state or a consumer protection agency, then files renewals or annual financial reports. Some states accept a copy of IRS Form 990 in place of all or part of their own report.
NASCO's state survey, last compiled in October 2026, classifies a large majority of states, plus the District of Columbia, as having general or limited registration requirements. Each state sets its own rules, and NASCO, the association of state charity regulators, keeps a list of state charity regulators with links to each office.
Does a Donate button on our website count as soliciting in other states?
It can. The main reference is the Charleston Principles, which NASCO's board approved as advisory guidelines on March 14, 2001. They state that "Existing registration statutes generally, of their own terms, encompass and apply to Internet solicitations." They are guidance, not law, and note "that the laws of individual states vary."
Your home state
If your principal place of business is in a state that requires registration and you solicit online, the Principles say you must register there. That holds "without regard to whether the Internet solicitation methods it uses are passive or interactive."
Other states
A charity based elsewhere should register in a state if its offline activity there already requires it. It should also register if it solicits through an interactive website and either:
- "Specifically targets persons physically located in the state for solicitation," or
- "Receives contributions from the state on a repeated and ongoing basis or a substantial basis through its Web site."
A site is interactive if a donor can complete a gift online, "even if completion requires the use of linked or redirected sites," and "regardless of whether donors actually use it." A WordPress donation form that takes cards through Stripe, or sends donors to PayPal, fits that definition.
A site that only asks donors to mail a check is not automatically outside the test. The same two conditions apply to it.
What counts as targeting a state?
Targeting means an express or implied reference on your website to soliciting from that state, or other appeals to its residents, "such as by advertising or sending messages to persons located in the state," when you know or reasonably should know where they are. Email appeals count like phone calls or direct mail when you know, or should know, where the recipient is. A charity working in a limited area does not target other states if its website "makes clear in context that their fundraising focus is limited to that area."
How many gifts is "repeated and ongoing"?
The Principles leave the number to each state. They ask states to set and publish levels, counting contributors for "repeated and ongoing" and dollars or a share of total contributions for "substantial." Their example, one hundred online contributions or $25,000 in a year, is only an illustration. We found no authoritative list of states that adopted any figure, so do not treat it as a safe harbor.
Registration and enforcement are separate. Section II says states will act against anyone whose online solicitations "mislead or defraud persons physically located within a particular state," whether or not it is based or required to register there.
Which states do not require charities to register?
A minority, and the list changes, so confirm with the state itself. Two regulators state it plainly:
- Idaho. The attorney general's FAQ says: "ICAPA does not require charitable organizations and those who solicit contributions on their behalf to register with the Attorney General." A charity that sells goods or services through unsolicited phone calls must still register as a telephone solicitor.
- Vermont. The attorney general's board guidance, dated October 2025, says: "Vermont law does not require charities to register with the Attorney General." The same office runs a separate registration for paid fundraisers.
NASCO's 2026 survey records no initial or annual charity registration in Delaware, Idaho, Indiana, Nebraska, South Dakota, Vermont and Wyoming. It lists narrow requirements in others, such as Arizona (veterans' charities) and Texas (public safety and veterans' groups, and law enforcement groups soliciting by phone). Use it as a starting point only: its map shading does not always match its own state entries, and paid-fundraiser or telephone rules can apply even where charities need not register.
Are small organizations and churches exempt?
Often, but every state draws the line differently, and exempt does not always mean no paperwork. Three examples:
- New York. Executive Law Article 7-A "shall not apply to corporations organized under the religious corporations law, and other religious agencies and organizations," and organizations they control. A charity that "solicits or receives gross contributions of less than twenty-five thousand dollars" in a fiscal year need not register if no professional fund raiser or fund raising counsel does its fundraising. If it passes $25,000, it must register within thirty days.
- Pennsylvania. The Department of State excludes religious institutions that meet its conditions, such as being tax-exempt. It exempts a charity that "receives gross national contributions of $25,000 or less annually" if it does not pay anyone to solicit. The threshold is worded as national contributions, so confirm with the Bureau before you count only Pennsylvania gifts.
- Connecticut. Religious corporations, institutions and societies are exempt from the full requirements and filing fees. So is a charity that "normally receives less than fifty thousand dollars in contributions annually," if it does not pay anyone primarily to solicit. Connecticut still has exempt organizations claim the exemption online.
What do some states require on the donation page and receipts?
Some states require a set statement. Two examples:
- Florida. Section 496.411(2) requires every charity soliciting in Florida to state, at the point of solicitation, its name, the state of its principal place of business and the purpose of the solicitation. Section 496.411(3) requires a charity that must register, or is exempt under one specific provision, to display this statement "on every solicitation, confirmation, receipt, or reminder of a contribution": "A COPY OF THE OFFICIAL REGISTRATION AND FINANCIAL INFORMATION MAY BE OBTAINED FROM THE DIVISION OF CONSUMER SERVICES BY CALLING TOLL-FREE WITHIN THE STATE. REGISTRATION DOES NOT IMPLY ENDORSEMENT, APPROVAL, OR RECOMMENDATION BY THE STATE." It must include the division's toll-free number and website. Online, it must be "conspicuously displayed on any web page that" lists a mailing address or phone number for giving, or "provides for online processing of contributions." Registered charities must also show their Florida registration number on every printed solicitation, written confirmation, receipt or reminder.
- New York. Under Executive Law section 174-b, solicitations by a registered charity that files financial reports must tell donors that, on request, they can get a copy of the organization's last financial report from the organization or from the charities registry on the attorney general's website. In written materials, the statement must be in at least ten-point bold type, or no smaller than most of the other text.
In Donor Merchant, the form sits on an ordinary WordPress page, so add the text above or below it. For printable receipts and year-end statements, use Settings, Email, Printable receipts, Custom receipt statement. That box replaces the standard tax language, so include your tax wording in it too. For emails, add the text to each email's message or to the template's Footer text.
Is there one place to register in every state?
Not that we could confirm. The Unified Registration Statement, organized by NASCO and the National Association of Attorneys General, is an alternative form that cooperating states accept. Its own site now says it "has limited utility today since most states require online filing."
In 2018, NASCO, the nonprofit Multistate Registration and Filing Portal (MRFP), GuideStar and CityBase announced a single national registration system. A portal page still lists Georgia and Connecticut, but Connecticut's own registration page sends charities to its eLicense system without mentioning it, and NASCO's resources page does not list it. We could not confirm it is in current use, so plan on filing with each state.
The IRS does not register you with states, but Form 990 asks about them. The 2025 instructions for Part VI, line 17 say: "List the states with which a copy of this Form 990 is required to be filed, even if the organization hasn't yet filed Form 990 with that state." The instructions add: "Some states require or permit the filing of Form 990 to fulfill state exempt organization or charitable solicitation reporting requirements."
How do you find out which states your donors live in?
You need two numbers per state and fiscal year: how many gifts, and how much money. Those map onto "repeated and ongoing" and "substantial."
If you use Donor Merchant, know what it records today. The form asks for first name, last name, email and an optional phone number, not a mailing address or state. The only address it collects is for UK Gift Aid, on sites taking pounds sterling. So the Donations CSV export cannot tell you a donor's state on its own.
The fix is a custom field, which the plugin supports for free:
- Go to Donor Merchant, Settings, Forms and scroll to Custom fields.
- Add a field labeled "State" with the type Dropdown. Type the choices in Options, separated by commas: the states you need, District of Columbia, and "Outside the US".
- Tick Required if you want an answer on every gift. If you leave it optional, expect gaps.
- Save, make a small test gift, and check that the answer appears in the new-donation email and in the CSV export.
Each answer is saved with the donation and appears in the Donations CSV under Custom Fields, as "State: Ohio". Plan for three gaps:
- Recurring renewals. Each renewal is recorded as a new donation without the custom field answer. In your spreadsheet, match renewals to the donor's first gift by email address.
- Older gifts. Gifts made before you added the field have no answer. Stripe's card form can collect a donor's country and postal code, but that stays in your Stripe account; Donor Merchant does not copy it.
- The Donors export. The Donors CSV does not include custom field answers. Work from the Donations export.
Then filter to completed gifts in your fiscal year and count gifts and dollars by state.
What order should you do this in?
- Register in your home state, or confirm and claim your exemption there.
- Start recording donor state on every gift.
- Check your appeals for targeting: ads aimed at a state, or emails to people you know live there.
- At least once a year, count gifts and dollars by state.
- For each state with real giving, read the regulator's page for requirements, exemptions and disclosure wording.
- Add required statements to the donation page, receipts and emails, and put renewal deadlines in a shared calendar.
- When the answer is unclear, ask the state regulator or a nonprofit attorney.
Still waiting on your IRS determination? See accepting donations before 501(c)(3) approval. Custom fields are described on the funds and custom fields page.
Sources
- NASCO, The Charleston Principles: Guidelines on Charitable Solicitations Using the Internet (approved March 14, 2001) (read October 2026)
- NASCO, Resources (read October 2026)
- NASCO, State Charities Registration Survey, last compiled October 2026 (read October 2026)
- NASCO, State Government Resources (state charity regulators) (read October 2026)
- Idaho Attorney General, Idaho Charitable Assets Protection Act FAQ (read October 2026)
- Vermont Attorney General, Understand Your Responsibilities: Guidance for Board Members of Charitable Nonprofits (read October 2026)
- Vermont Attorney General, Paid Fundraisers (read October 2026)
- New York Executive Law section 172-a, Exemptions (read October 2026)
- New York Executive Law section 174-b, Disclosure requirements (read October 2026)
- Pennsylvania Department of State, Excluded or Exempt Charity Organizations (read October 2026)
- Connecticut Department of Consumer Protection, Charitable Solicitation Registration Information (read October 2026)
- Florida Statutes section 496.411, Disclosure requirements and duties of charitable organizations and sponsors (read October 2026)
- Multi-State Filer Project, The Unified Registration Statement (read October 2026)
- NASCO, GuideStar, MRFP and CityBase announcement, April 4, 2018 (read October 2026)
- MRFP, The State Charity Registration Portal (read October 2026)
- IRS, 2025 Instructions for Form 990 (read October 2026)
- Stripe, Create the Payment Element (billing details collection) (read October 2026)