.svg)
California AB 488 and Hawaii SB 1048 both regulate internet-based services that enable charitable solicitations, but their operating rules are not identical. A platform serving people in either state may need to register before enabling solicitations, verify charity eligibility, obtain or document charity consent, display donor disclosures, protect charitable funds, and complete ongoing filings.
California's framework has applied since 2024 and uses Forms PL-1 through PL-4. Hawaii's amended law, enacted as Act 108, took effect July 1, 2026 and now has an active registration process. Teams operating in both states should use one control map, then document the state-specific differences described below.
Both states regulate more than traditional crowdfunding websites. A charitable fundraising platform can include an internet-based service that permits or enables charitable solicitations, even when another party receives or distributes the funds.
California's charitable fundraising platform guidance organizes covered activity into five solicitation types. They include direct or recommended donations, peer-to-peer fundraising, donations connected to purchases or other user activity, and customizable fundraising software for charities.
Hawaii's official platform FAQ describes a similar range. Its examples include charity catalogs, peer-to-peer campaigns, purchase-linked donations, action-triggered company donations, and customizable fundraising pages or software. Hawaii also states that an out-of-state company can be covered when its service is provided to people in Hawaii and enables charitable solicitations there.
In both states, classification depends on what the product actually does. A payment processor or technical vendor is not automatically a platform when it only provides back-end services, but a provider that lists charities, presents solicitations, enables campaigns, or controls donation flows may require a different analysis.
The two laws also recognize platform charities. A platform charity is generally a charitable organization that facilitates solicitations on a platform, such as by receiving donations and making grants to charities selected by donors. A recipient charity listed on a platform is not automatically a platform charity.
The core obligations overlap, but the filing calendar, charity-status test, consent model, and platform-charity process differ.
Sources: California Attorney General guidance and regulations, and Hawaii Attorney General guidance and Act 108. Reviewed September 24, 2026.
California requires a covered platform to file Form PL-1 before it begins covered activity. It then renews with Form PL-2 by January 15 and reports the prior calendar year's activity on Form PL-4 by July 15. A California platform charity may also need Form PL-3 within 30 days after entering a platform partnership, unless the required notice was provided through another permitted filing.
Hawaii requires a covered platform to register before it solicits, permits, or enables charitable solicitations. A platform already operating on July 1, 2026 had to register before continuing covered activity. Hawaii's annual platform renewal date is July 1, and its online charities portal now links to registration and search tools for charitable fundraising platforms and platform charities.
The biggest differences appear in charity eligibility, consent, filing mechanics, and the controls that sit around donor and vendor interactions.
California generally requires platforms to evaluate charity status using information from the California Attorney General, the IRS, and the California Franchise Tax Board. The state's regulations contain detailed rules for when a charity is treated as in good standing and what a platform must do when status changes.
Hawaii directs platforms and platform charities to its Attorney General registry. The state says a charity is in good standing for these platform provisions when it has an active registration or active exemption on file, and its online list is updated nightly. A shared eligibility service therefore needs state-specific data sources rather than one national status flag.
California permits certain solicitations for a non-consenting charity, but the platform must follow specific conditions, disclosures, removal rights, and distribution rules. Written consent is still the cleaner operating model for many programs, particularly when the campaign suggests an active relationship with the charity.
Hawaii requires written consent before a platform or platform charity uses a recipient charity's name in a solicitation. The consent must come from an authorized officer, director, trustee, or other authorized representative. One consent document can cover multiple affiliated platforms when those platforms are expressly identified.
Hawaii requires a charitable fundraising platform to maintain and operate a complaint process, investigate complaints, make findings, and report findings and resolution actions when requested by the Attorney General. Hawaii's final law also requires certain vendor contracts to be available for inspection.
The final law does not impose the earlier proposed rule that every platform-charity contract be filed before fundraising begins. That distinction matters for launch planning. Teams should retain applicable contracts and consents in an inspection-ready record, but they should not build a filing workflow around language that did not survive into Act 108.
A multi-state program should begin with one product and funds-flow map. The map should show who presents each solicitation, who selects the charity, who receives the donor's payment, who issues the receipt, where funds are held, and who sends the final payment or grant.
Use that map to build six controls:
The platform should also retain records for regulator review. Hawaii's current guidance says covered platforms and platform charities must keep activity records for at least three years. California's platform regulations require records that support registration, reporting, solicitation, consent, receipt, accounting, and distribution obligations.
Teams should assign owners across legal, product, finance, and operations. Legal can interpret coverage and consent terms, product can place the correct disclosure in each flow, finance can protect and reconcile funds, and operations can manage status checks, filings, receipts, and payouts. The system should preserve an audit trail across all four functions.
For a deeper California implementation review, see Change's AB 488 guide for charitable fundraising platforms. Change also explains the Hawaii framework in its Hawaii platform compliance guide. Companies that want a consolidated workflow can review Change's charitable fundraising platform solution for registration, consent, verification, reporting, and donation operations.
Yes. Hawaii's amended charitable fundraising platform requirements took effect July 1, 2026. A covered platform must register before beginning covered activity, and a platform already operating on that date had to register before continuing.
Hawaii requires a charitable fundraising platform or platform charity to obtain written consent before using a recipient charity's name in a charitable solicitation. The state does not currently prescribe a standard consent form, but the consent must come from an authorized representative.
Not in every permitted model. California allows a limited path for certain solicitations involving nonconsenting charities, subject to specific conditions, disclosures, removal rights, and distribution requirements. Platforms should review the exact solicitation type and regulations before relying on that path.
Hawaii's final Act 108 did not retain the proposed blanket requirement to file a platform's contracts with charities before fundraising. Certain vendor contracts must instead be kept available for Attorney General inspection, while written charity consent remains required.
One workflow can centralize product mapping, consent, disclosures, charity status, funds controls, and audit records. It still needs state-specific rules for registration forms, renewal dates, eligibility sources, platform-charity filings, and California's solicitation-type timing requirements.
This article provides general information, not legal advice. Coverage and filing duties depend on the platform's activities, contracts, funds flow, users, and jurisdictions. Consult qualified counsel about a specific program.
.png)