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California AB 488 requires covered charitable fundraising platforms to register before enabling solicitations and to maintain controls for nonprofit eligibility, consent, disclosures, receipts, charitable funds, payouts, and annual reporting. Companies should start by mapping their exact online giving model because the law covers more than traditional crowdfunding websites.
This checklist is designed for legal, product, finance, and social impact teams evaluating a new or existing program. It is not a substitute for advice about a specific platform or campaign.
AB 488 can apply when an internet-based service reaches people in California and performs, permits, or enables charitable solicitations. The statutory definition includes platforms that list charities for donations, enable peer-to-peer campaigns, let users choose a nonprofit that benefits from purchases or other activity, select nonprofits for company-funded giving tied to user activity, or provide customizable fundraising software to charities.
The definition also contains exclusions. For example, a charity's own platform that solicits only for itself is not a charitable fundraising platform. A vendor that solely supplies technical or payment-processing support may also be excluded, but the analysis changes if that vendor enables solicitations on its own platform.
The California charitable fundraising platform statute also addresses overlap with commercial fundraisers and commercial co-venturers. A company should not choose its category from marketing language alone. Counsel should review the actual user experience, agreements, funds flow, nonprofit choice, and consideration offered to donors.
Document who asks for the donation, who supplies the funds, who appears in the user interface, who initially receives the money, and how the nonprofit is selected. California's regulations describe five solicitation types covering direct platform donations, peer-to-peer fundraising, user-selected cause marketing, platform-selected cause marketing, and customizable software for charities.
Classification affects consent, disclosures, payout timing, receipts, and reporting. A single company may support more than one type, so map each product flow separately.
A covered charitable fundraising platform must register with the California Attorney General before performing, permitting, or enabling solicitations. Registration began on June 12, 2024.
The state's platform filing guidance identifies three recurring deadlines: initial Form PL-1 before activity begins, Form PL-2 renewal by January 15 for each operating year, and Form PL-4 annual reporting by July 15 for the prior calendar year. A platform charity may also need Form PL-3 after entering a partnership with a platform.
Treat filings as an operating dependency. Store registration numbers, submission copies, signatory approvals, renewal status, and the data needed for the annual report.
Covered platforms may only solicit, receive, control, or distribute donations for charitable organizations in good standing. California defines good standing by reference to federal tax-exempt status, California Franchise Tax Board status, and whether the Attorney General prohibits the organization from operating or soliciting in the state.
Build recurring checks, not a launch-day review. The IRS Tax Exempt Organization Search is one input, while California's Registry Search Tool and May Not Operate list address state status. Store the result, source, and time of each check.
The default rule requires written consent before a covered platform or platform charity uses a recipient charity's name in a solicitation. The agreement must come from an authorized representative and address required terms such as fees and payout timing.
California also permits certain solicitation types to reference a non-consenting charity if the platform follows additional conditions. Those include limiting the information displayed, disclosing that the charity has not consented, honoring verified removal requests, and not conditioning receipt of funds on consent.
Consent should be a managed status with the agreement, authorized signer, covered platforms, effective date, terms, and withdrawal history attached.
For applicable solicitation types, donors must receive conspicuous information before completing a donation or changing a nonprofit selection. Required topics can include who receives the donation, why a selected charity might not receive funds, the maximum payout timeline, fees, and tax deductibility.
The disclosure must be easy to notice and placed near the content it explains. Review the full journey, including mobile screens. California's regulations also require certain tax donation receipts within five business days after the donation.
Charitable funds cannot be diverted, misused, or commingled with other money belonging to the platform or platform charity. The ledger should distinguish donations, fees, refunds, pending funds, and amounts sent to each recipient.
Payout timing depends on solicitation type and consent status. Under the California platform regulations, certain donations for consenting charities must be sent no later than 30 days after month-end, while qualifying non-consenting models can have a 45-day deadline. Other solicitation types use quarterly or five-business-day rules.
Do not apply one headline deadline to every product. Tie the rule to the classified flow and track exceptions for ineligible recipients.
AB 488 compliance depends on transaction-level evidence. The system should connect solicitations, donations, fees, donor-sharing choices, recipient charities, eligibility results, receipts, payouts, alternate recipients, and relevant dates.
The annual Form PL-4 asks about fundraising activity from the prior calendar year. Recipient charities must also receive prescribed information about funds sent through covered platforms. Design reports from the ledger rather than trying to reconstruct activity at the filing deadline.
AB 488 becomes easier to manage when every control has a clear owner. This starting point can be adapted to the company's structure:
The owner may vary, but the control should not disappear between teams. Change's guide to what legal teams want marketers to prepare offers a useful model for cross-functional planning.
No. The definition can cover checkout donations, peer-to-peer tools, corporate giving portals, cause marketing programs with nonprofit choice, and customizable fundraising software. Applicability depends on the actual online activity and statutory exclusions.
Written consent is the default rule, but California allows a limited non-consenting path for certain solicitation types that meet additional conditions. Teams should not assume that public nonprofit information alone satisfies those conditions.
No. California's regulations use different schedules based on solicitation type and consent status. Some flows use 30 or 45 days after month-end, some use quarterly schedules, and certain customizable charity platforms use a five-business-day rule.
The platform may need to stop soliciting, holding, or sending funds for that organization and follow the applicable alternate-recipient process. Eligibility should therefore be checked throughout the donation lifecycle, not only when the nonprofit joins.
AB 488 compliance is not one filing. It is a connected system of registration, charity status, consent, donor information, funds handling, payout timing, and reporting. Companies that assign owners and build evidence into the product are better prepared to operate consistently as volume grows.
Change's charitable fundraising platform solution supports these workflows across consent, verification, filings, donations, payouts, receipts, and reporting.
This article provides general information and does not constitute legal advice. Consult qualified counsel about the requirements that apply to a specific platform or campaign.
