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Professional Fundraisers

Fundraising disclosure requirements for online campaigns

Sonia Nigam, Change
Sonia Nigam
October 5, 2025
Blog
Professional Fundraisers
Fundraising disclosure requirements for online campaigns
Last Updated:
October 5, 2025
Sonia Nigam, Change
Sonia Nigam

Fundraising disclosures should tell a prospective donor who is soliciting, which charity benefits, how the transaction works, and any other information required by the applicable jurisdiction and campaign type. There is no single disclosure that works for every state, channel, professional fundraiser, sweepstakes, platform, or donor-advised fund structure.

The practical goal is to translate the legal analysis into accurate language that appears at the right moment in the donor journey. The disclosure must also match the contracts, payment flow, receipts, reports, and records behind the campaign.

Why do fundraising disclosure requirements vary?

States regulate charitable solicitation through different definitions, exemptions, registration rules, contract requirements, disclosures, and reporting systems. The regulated role may be called a commercial fundraiser, professional fundraiser, professional solicitor, fundraising counsel, commercial co-venturer, charitable fundraising platform, or another term.

The California Attorney General's professional fundraiser guidance explains that a commercial fundraiser can be paid to solicit through direct mail, telephone, email, internet platforms, auctions, event tickets, vehicle donations, or thrift-store operations. The New York Attorney General's fundraiser guidance states that fundraising professionals may need annual registration, contract filings, and financial reports.

Those examples show why disclosure review should begin with classification. A professional fundraiser soliciting on a charity's behalf has different obligations from a business promising a company-funded donation with each purchase. An online platform that enables donations to multiple charities may also fall under a separate platform statute.

Channel matters too. A telephone script, sweepstakes landing page, checkout module, social advertisement, event sign, and emailed solicitation offer different space and timing. The legal requirement may apply before the donation, during the solicitation, in a written confirmation, or through a link that must remain clear and conspicuous.

What information should a disclosure review cover?

The required wording depends on law and campaign facts, but a review should answer the following questions before creative is approved.

Disclosure topicQuestion to answerRecord to verify
Soliciting partyWho is asking?Registration and contract
BeneficiaryWhich charity benefits?Legal name and consent
TransactionWhat does the donor pay?Checkout configuration
Funds flowWho receives and grants funds?Payment-flow map
Fees or costsWhat may be deducted?Agreement and pricing
Campaign limitsWhat dates or caps apply?Approved campaign terms
Tax treatmentWhat receipt is provided?Receipt policy
State noticesWhich wording is required?Jurisdiction matrix

Sources: California and New York Attorney General fundraiser guidance. Reviewed September 24, 2026.

Use the charity's full legal name when required, and confirm that public use of its name and marks matches written authorization. If a campaign benefits several charities, explain how selection occurs and what happens if a selected organization cannot receive funds.

When a donor-advised fund or platform charity receives the initial contribution and later recommends or makes a grant, describe the structure accurately. Do not identify a downstream nonprofit as the legal recipient of a donor's contribution if the transaction is legally made to another charitable organization. The language should also avoid promising a grant before eligibility and program conditions are satisfied.

How should disclosures appear in an online fundraising flow?

Place the information where a reasonable person will encounter it before completing the donation or other triggering action. A disclosure hidden in terms that appear only after payment may not provide meaningful notice, even if the same wording would be adequate when presented beside the contribution control.

Use layered disclosure when the full explanation is too long for the primary screen. The first layer should contain the facts that materially affect the donor's decision. A clearly labeled link can lead to campaign rules, state notices, eligibility details, privacy terms, or a longer funds-flow explanation.

Review the complete journey on mobile and desktop:

  • Advertisement or referral page.
  • Campaign landing page.
  • Donation or entry form.
  • Payment and confirmation screens.
  • Receipt or acknowledgment.
  • Follow-up email and donor account.

The same charitable promise should remain consistent across every surface. If the landing page says all proceeds benefit a charity but the checkout deducts a platform fee, the inconsistency is not solved by a small-print statement elsewhere. Update the headline claim, fee disclosure, and supporting records together.

Localization requires more than translating a sentence. The regulated party, required wording, charity status, donor location, and available entry or payment method may change by jurisdiction. Maintain an approved disclosure library with version, jurisdiction, channel, and effective-date fields instead of allowing teams to copy language from an unrelated campaign.

Sweepstakes and prize promotions require a separate legal review. The official rules, eligibility, entry method, prize description, dates, odds or selection method, and any free method of entry may be governed by laws beyond charitable solicitation rules. Do not use a generic fundraiser disclosure checklist as a substitute for promotion counsel.

Managing fundraising campaigns across multiple states?

Change helps professional fundraisers manage registrations, contracts, campaign records, reporting, nonprofit verification, and payouts in one workflow.
Explore fundraiser compliance

How can teams keep disclosures accurate after launch?

Disclosure compliance depends on change control. New charities, added states, extended dates, revised prizes, different donation amounts, new fees, and altered payment routing can make approved language incomplete or inaccurate.

Create a disclosure record for each campaign version. Store the approved wording, reviewer, effective date, covered channels, screenshots, linked terms, charity authorization, agreement, and funds-flow diagram. Connect changes in the campaign configuration to a required legal and operational review.

Test the live experience before accepting contributions. Confirm that the correct charity, amount, dates, limits, and required state notices display for the intended user and device. Complete a test transaction and compare the checkout, receipt, ledger, and payout instructions.

Schedule a review during longer campaigns. A charity can change its name or status, a regulator can update a required notice, or the product can introduce a new payment path. Periodic review helps the team identify drift before it affects a large number of solicitations.

Professional fundraisers should also coordinate public disclosures with registration, contract, and reporting data. A regulator or charity should be able to reconcile the solicitation the donor saw with the contract terms, gross revenue, expenses, net amount, and funds delivered.

Change's professional fundraiser solution supports multi-state compliance, campaign records, reporting, donation operations, and payouts. Teams running charitable sweepstakes can review Change's sweepstakes and auctions solution, while platform operators should evaluate the separate charitable fundraising platform requirements.

Frequently asked questions

Is naming the charity enough?

Not necessarily. Applicable law or the campaign structure may require information about the solicitor, charitable purpose, fees, funds flow, dates, limits, registration, tax treatment, or other terms.

Can required information appear only in terms and conditions?

That depends on the requirement and presentation. Material facts should generally appear clearly before the donor acts. Use a layered approach for supporting detail, and have counsel approve the placement.

Does state registration mean a regulator endorses the fundraiser?

No. Registration is a regulatory filing, not an endorsement. Some jurisdictions require specific statements explaining that distinction, so review current state language.

Does a donor-advised fund remove disclosure obligations?

No. A donor-advised fund changes the legal and operational structure, but the donor still needs an accurate explanation of the recipient, intended beneficiary, fees, grant process, and receipt.

Who should approve fundraising disclosures?

Qualified counsel should determine legal requirements. Marketing, product, finance, operations, and the charity should confirm that the language matches the live experience, agreement, records, and funds flow.

This article provides general information, not legal advice. Disclosure duties vary by jurisdiction, regulated role, channel, and campaign. Consult qualified counsel.

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