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Online giving has outgrown the legal framework that was built for direct mail and telethons. State regulators are responding with a new category of oversight aimed at the systems that sit between donors and nonprofits.
California moved first with AB 488, which established a compliance regime for “charitable fundraising platforms” and “platform charities,” followed by detailed regulations and required filings that began taking effect in 2024. Hawaii followed with SB 1048, which amends Hawaii’s platform fundraising law and extends the effective date to July 1, 2026.
Both laws share the same policy goal: protect donors and nonprofits by requiring consent, transparency, and predictable fund handling. The implementation details differ in ways that matter for product, legal, and operations teams.
California defines a charitable fundraising platform broadly as an entity that uses the internet to provide a website, service, or other platform to people in California and performs, permits, or enables solicitations to occur. This definition captures many modern giving flows, including donation prompts embedded in ecommerce, customer “round-up” experiences, and platform-enabled fundraising.
Hawaii’s definition tracks closely with California’s and covers any person that uses the internet to provide a website, service, or other platform to people in the state and performs, permits, or enables acts of solicitation to occur.
If your product enables donors to give to nonprofits through your user experience, and the solicitation reaches residents in either state, these frameworks deserve a serious read.
Below is a side-by-side checklist of the core operational requirements teams are planning around today, followed by a few notes that explain what tends to surprise companies during implementation.
California’s “good standing” test is multi-source. AB 488 ties platform eligibility to three regulators: IRS, California Franchise Tax Board, and the California Attorney General. The regulations also include a narrow five business day grace period tied to when a charity appears on the Attorney General’s “May Not Operate or Solicit” list.
Hawaii adds a contract filing requirement. SB 1048’s amended text requires a written contract to be filed with the Attorney General before any fundraising activity by a charitable fundraising platform or platform charity. This is a meaningful operational obligation that impacts onboarding and launch timelines for many companies.
Hawaii is more prescriptive on records and complaints. SB 1048 specifies record categories that must be maintained for at least three years and requires a defined complaints process, including investigation and reporting to the department upon request.
If your product enables online charitable solicitations, a useful next step is a structured internal assessment that ties product flows to regulatory obligations.
Many teams choose to manage these requirements through centralized infrastructure that handles consent capture, charity status monitoring, disclosure workflows, payout schedules, and reporting exports in one system. For platforms and brands running multi-state giving programs, that approach reduces internal coordination overhead and keeps compliance work aligned with product growth.
Conclusion
California AB 488 established the first modern framework for charitable fundraising platforms at scale, and Hawaii SB 1048 signals where state oversight is headed next. The practical differences matter. California emphasizes multi-source good standing checks, defined disclosure structures, and timing rules keyed to solicitation type. Hawaii adds contract filing, prescriptive recordkeeping, and a formal complaints process, with additional details expected through Attorney General guidance.
Companies that begin planning now will be in a stronger position by July 2026. Mapping your product flows, building scalable consent, tightening disclosures, and making reporting and disbursement operationally reliable will pay off across both regimes.
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