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Compliance Insights

Online fundraising enforcement: Alaska and California lessons

Amar Shah, Change
Amar Shah
March 19, 2026
Blog
Compliance Insights
Online fundraising enforcement: Alaska and California lessons
Last Updated:
March 19, 2026
Amar Shah, Change
Amar Shah

Recent actions in Alaska and California show that online fundraising platforms should treat nonprofit authorization, disclosures, registration, funds flow, payout, and records as product requirements. The Alaska matters are lawsuits containing state allegations, and California's public actions and guidance should be read in their specific procedural context.

The practical lesson is broader than any one company: a platform should be able to explain why a charity appears, what the charity authorized, who receives the donation, what the donor sees, when funds move, and which record proves each step.

What happened in Alaska and California?

On March 10, 2026, the Alaska Attorney General announced lawsuits against six online fundraising companies. The state's press release alleges that platforms created fundraising pages for charities without their knowledge or consent and that the pages could create confusion about authorization, fees, and delivery.

Those statements are allegations in pending litigation, not final judicial findings. Platforms evaluating the development should review the complaints and later court records with counsel rather than treating the press release as the complete record.

California has developed a detailed statutory and regulatory framework for charitable fundraising platforms. The California Attorney General's platform guidance, updated August 25, 2026, explains registration, annual reports, good-standing checks, disclosures, consent, receipts, donation delivery, accountings, and user access to donation status.

California does not make affirmative charity consent the only possible pathway in every circumstance. Its guidance states that solicitations for non-consenting charities must comply with Government Code section 12599.9(f)(2), while consent-based solicitations must meet the agreement requirements that became effective January 1, 2025.

California's rules therefore require a platform to know which pathway it is using and implement the corresponding eligibility, disclosure, notification, and fund-handling controls. A charity directory assembled from public data is not a substitute for that legal and product analysis.

Which platform controls deserve immediate review?

Start with the end-to-end user and funds flow. Review the search page, charity profile, campaign creation, donation form, checkout, receipt, refund, payout, status page, accounting, and annual report as one system.

ControlQuestionEvidence
AuthorizationWhy is the charity listed?Consent or legal pathway
EligibilityMay it receive funds?Status check
DisclosureWhat does the donor see?Versioned screen
Funds flowWho holds and sends money?Ledger and payout
ReportingCan activity be reconstructed?Campaign record

Sources: Alaska Department of Law and California Attorney General. Reviewed September 24, 2026.

Authorization should be tied to the legal entity, authorized signer, permitted programs, approved name and logo use, channels, dates, geography, and termination status. Store the effective agreement or the documented basis for a non-consenting pathway.

Eligibility monitoring should run before solicitation and before payout, with clear outcomes for a charity that is delinquent, suspended, dissolved, sanctioned, or otherwise ineligible. The process should not silently redirect funds without the required disclosure and rule.

Disclosures should identify the soliciting parties, recipient, fees, timing, conditions, tax treatment, and alternate-recipient process when applicable. Test the actual mobile and desktop experience, not just a legal copy document.

Funds must be separated, traceable, and reconciled according to the governing requirements and agreements. Every donation should connect to the donor-facing promise, receipt, ledger entry, refund, fee, payout, and accounting.

How should consent and charity status work in the product?

Treat consent as a lifecycle, not a checkbox. Onboarding, renewal, scope changes, revocation, termination, and offboarding all need defined states and owners.

Bind the visible charity profile to the authorization state. If the agreement expires or the charity withdraws permission, the platform should know which pages, campaigns, links, logos, and recurring donations are affected.

For a non-consenting-charity model permitted by applicable law, document the legal basis and implement its specific disclosure, contact, distribution, alternate-recipient, and status requirements. Do not present that charity as a platform partner.

California distinguishes charitable fundraising platforms, platform charities, and recipient charitable organizations. Responsibilities can depend on the partnership and funds flow. The platform's contracts and product labels should match those actual roles.

Use reliable charity identity fields and avoid merging organizations based only on similar names. Save the source, lookup date, status result, exceptions, and reviewer for eligibility decisions.

Review your platform compliance controls

Change helps online fundraising platforms manage nonprofit consent, eligibility, donation records, payouts, reporting, and audit-ready workflows.
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Give charities a way to correct information, understand activity, receive accountings, and report misuse. A support form without identity verification, routing, or service levels is not a complete control.

What should a platform do next?

Run a privileged, cross-functional review led by counsel. Product, engineering, compliance, finance, operations, support, and partnerships should test the system against current laws, regulations, agreements, and regulator guidance.

  1. Inventory every charity page and fundraising flow.
  2. Map legal roles, consent pathways, jurisdictions, and partners.
  3. Test registration, good standing, disclosure, and receipt controls.
  4. Reconcile donations from checkout through payout and accounting.
  5. Validate records for annual reports and regulator inquiries.
  6. Define remediation, escalation, and change management.

Prioritize gaps that can mislead users or prevent funds from reaching the intended charity. Freeze expansion when the platform cannot identify the authorization, eligibility, funds flow, or payout status behind a live solicitation.

Review Change's California AB 488 guide and charitable fundraising platform requirements explainer for more detail on California's framework.

Change's charitable fundraising platform solution supports nonprofit consent, eligibility monitoring, payouts, records, and compliance workflows. Platform operators and counsel remain responsible for classification and legal conclusions.

Test legacy pages and cached search results, not only newly created campaigns. Old profiles can remain discoverable after a platform changes its onboarding policy. Inventory redirects, embedded widgets, partner links, and indexed pages that may continue accepting donations.

Review fee presentation and accounting together. The donor-facing screen, receipt, platform ledger, payment-processor record, charity accounting, and payout should describe the same gross donation, fees, net amount, and timing.

Measure how long exceptions remain unresolved. Track charities awaiting consent, donations awaiting eligibility review, returned payouts, missing accountings, and user status inquiries. Aging reports can reveal a control that exists on paper but does not work at scale.

Preserve the exact version of disclosures and terms shown for each transaction. A current webpage cannot prove what a donor saw months earlier after the copy has changed.

Assign an executive owner to review the remediation plan, resource needs, and residual risk. Platform compliance spans product and operations, so unresolved gaps cannot remain only in a legal issue tracker.

Frequently asked questions

Did Alaska courts find that the six platforms violated the law?

The March 10, 2026 announcement describes allegations in lawsuits. A press release is not a final court ruling, so review the litigation record for later developments.

Does California always require affirmative charity consent?

No. California provides a regulated pathway for certain solicitations involving non-consenting charities, with specific requirements. A platform must identify and comply with the applicable pathway.

What is a platform charity in California?

A platform charity is a charity in a contractual partnership that facilitates solicitations on a charitable fundraising platform. Its responsibilities depend on the partnership.

How often should charity status be checked?

Check at the points required by law and the platform's risk controls, including before solicitation and distribution when applicable. Document the source, time, and result.

What records should an online fundraising platform retain?

Retain authorization, charity status, disclosures, receipts, donations, fees, refunds, ledger entries, payouts, accountings, filings, user status inquiries, and exception resolution under an approved policy.

This article provides general information, not legal advice. Laws, guidance, and litigation can change, so consult qualified counsel about a specific platform.

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