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Federal and state governments oversee different parts of charitable activity. The IRS administers federal tax-exempt status, annual information returns, and federal tax rules, while state charity regulators oversee solicitation, registration, paid fundraisers, charitable sales promotions, online platforms, governance, and misuse of charitable assets.
A nonprofit or fundraising partner can be compliant with one system and delinquent in another. Organizations should maintain a coordinated calendar without treating incorporation, Form 990, state charitable registration, and fundraiser filings as interchangeable.
The IRS determines and administers federal tax-exempt status under the Internal Revenue Code. It receives exemption applications, annual returns and notices, employment tax filings, unrelated business income returns, and other federal tax documents.
Most tax-exempt organizations must file a Form 990-series return or notice annually unless an exception applies. The IRS annual filing guidance explains the available forms and electronic filing rules.
An organization that is required to file and misses its Form 990-series obligation for three consecutive years generally loses federal tax-exempt status automatically. The IRS publishes information through Tax Exempt Organization Search, including status, filings, and automatic revocation data.
Federal tax exemption does not mean every activity is exempt from tax. The IRS explains that an organization can owe unrelated business income tax when it regularly carries on a trade or business that is not substantially related to its exempt purpose, subject to modifications, exclusions, and exceptions.
Other federal agencies can be relevant to specific activity. The Federal Trade Commission addresses deceptive marketing and endorsements, the Office of Foreign Assets Control administers economic sanctions, and the Department of Justice can pursue fraud and other federal violations. The responsible agency depends on the conduct, not simply the organization's nonprofit status.
States regulate the solicitation and stewardship of charitable funds under their own laws. The responsible office may be an attorney general, secretary of state, consumer protection agency, or another department.
A charitable organization may need to register before soliciting contributions, renew periodically, file annual financial reports, submit contracts, or provide audited financial statements. Exemptions and thresholds vary, and some require a separate application or notice.
States also regulate participants around the charity. Professional solicitors, professional fundraising counsel, commercial co-venturers, and online fundraising platforms can face registration, bond, contract, disclosure, accounting, and campaign-reporting duties.
For example, the California Attorney General maintains separate guidance for professional fundraisers and charitable fundraising platforms. Hawaii's charity portal likewise identifies charitable organizations, professional fundraisers, platforms, and platform charities as distinct registrant types.
State oversight can also reach governance, restricted gifts, conflicts of interest, transactions involving charitable assets, dissolution, and enforcement against fraud or diversion. Corporate annual reports and state tax filings may be handled by different agencies again.
The systems share information but serve different purposes. An IRS determination letter establishes federal tax status. It does not register the organization to solicit in every state. A state charity registration does not replace Form 990.
Source: IRS and state charity regulator guidance. Reviewed September 24, 2026.
Data should reconcile across systems even when forms use different definitions. Legal name, EIN, fiscal year, revenue, expenses, fundraising costs, related parties, and professional fundraiser activity may appear in several records.
Digital platforms increasingly make status checks operational. California and Hawaii platform laws regulate which organizations can be supported, what donors must see, how funds are handled, and what records and reports platforms maintain.
Create one compliance inventory with separate rows for federal tax, state corporate, state tax, charity registration, fundraising vendor, campaign, and platform obligations. Record the authority, form, period, due date, extension, signer, fee, status, source, and evidence of acceptance.
Connect fundraising intake to the inventory. Before a new state, vendor, platform, cause campaign, sweepstakes, or customer donation program launches, identify whether it changes the organization's registrations or creates duties for another party.
Assign owners for filings and regulator correspondence. A submission confirmation should not automatically mean accepted or complete. Track deficiencies, notices, amended filings, fees, and reinstatement through closure.
Reconcile reports with audited statements and Form 990 before filing. Document differences caused by reporting periods, state definitions, joint costs, campaign accounting, or restricted revenue.
For multistate filing operations, Change's charitable registration product helps legal teams and service providers organize data, documents, signatures, status, and renewals. Technology supports the workflow, while the organization and its advisers remain responsible for legal judgment and accuracy.
Begin with a written scope that identifies the legal entities, program owners, users, nonprofit population, jurisdictions, solicitation channels, funds flow, vendors, and launch date. A clear scope lets counsel and operations distinguish the rules that apply from controls that are simply good practice. Record open questions and the person responsible for resolving each one.
Create a source register for every recurring decision. For federal tax information, use the IRS Tax Exempt Organization Search and retain the date and result. For state requirements, use the National Association of State Charity Officials directory to locate the responsible regulator, then link the current form, instruction, statute, or guidance. Note that databases can update on different schedules and may use different organization identifiers.
Translate the research into a control matrix. For each requirement, document the trigger, jurisdiction, owner, due date, evidence, renewal rule, exception path, and review date. Connect the matrix to the underlying agreement, consent, registration, disclosure, transaction ledger, receipt, payout, accounting, complaint, and report. A status such as complete should always point to evidence.
Use technology for repeatable collection, validation, reminders, and records while preserving human review for classification and exceptions. Change's charitable registration workflows can help organize multistate filing data, and its nonprofit verification tools can support identity and eligibility checks. The organization and its advisers remain responsible for the policy and legal conclusions.
Set change triggers before launch. Re-review the workflow when the product, public language, nonprofit, state coverage, payment path, vendor, fee, or campaign mechanic changes. Monitor regulator notices, filing deficiencies, status changes, complaints, failed payouts, and unreconciled balances. Schedule a periodic control test in addition to deadline reminders, because a timely filing does not prove that customer disclosures, records, calculations, and disbursements still match the approved program.
Keep the current matrix accessible to every operational owner.
The IRS administers federal tax law. State charity regulators generally administer charitable solicitation registration and related fundraising rules.
Not by itself. Some states request Form 990 as an attachment, but they can require separate registration, renewal, financial schedules, fees, and signatures.
States commonly regulate professional solicitors and fundraising counsel under charitable solicitation laws. Definitions, registrations, bonds, contracts, and reports vary.
Platform laws and policies may restrict solicitation or disbursement for organizations that are not eligible or in good standing. Status can therefore affect access to donations.
Review it on a recurring schedule, before major campaigns, when fundraising activity changes, and whenever a regulator, funder, or platform raises a status issue.
This article provides general information, not legal or tax advice. Consult qualified advisers about the organization's activities and jurisdictions.
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