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CA AB 488 vs. HI SB 1048: Charitable Fundraising Platform Guide
A quick compliance guide comparing California and Hawaii’s fundraising platform rules.
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Compliance Insights

Hawaii charitable fundraising platform law: 2026 guide

Sonia Nigam, Change
Sonia Nigam
May 15, 2026
Blog
Compliance Insights
Hawaii charitable fundraising platform law: 2026 guide
Last Updated:
May 15, 2026
Sonia Nigam, Change
Sonia Nigam

Hawaii's charitable fundraising platform law took effect July 1, 2026. A covered charitable fundraising platform must register before enabling solicitations and should prepare for annual reports, written charity consent, conspicuous donor disclosures, charity good-standing checks, separate charitable funds, records, contracts, complaints, and prompt receipts and distributions.

Hawaii and California regulate similar online activity, but their definitions, consent pathways, filings, disclosures, records, and operational rules are not identical. Platforms need a Hawaii-specific implementation rather than a copy of a California checklist.

Who can be a charitable fundraising platform in Hawaii?

Hawaii's portal describes a charitable fundraising platform as an entity that uses the internet to provide a website, service, or platform to people in Hawaii and either solicits for charities or enables others to solicit.

The description includes services that list recipient charities to receive donations or grants based on purchases or other user activity. It also includes customizable websites, software, or other platforms that allow charities to solicit or receive donations, including peer-to-peer fundraising.

A platform charity is a charitable organization that facilitates solicitations on a platform. An organization that meets both definitions is treated as a charitable fundraising platform.

Classification depends on the actual product, parties, public message, and funds flow. A company should map who creates pages, selects charities, enables peer activity, receives funds, issues receipts, holds money, determines eligibility, sends donations, and handles complaints.

The Hawaii Attorney General's charities portal provides current registration links, definitions, a good-standing list, and frequently asked questions for platforms and platform charities.

What does the Hawaii platform law require?

The enacted framework requires registration before covered solicitation activity. It also creates annual reporting and renewal obligations, with forms and filing methods administered by the department.

Before a person completes a donation or selects a recipient charity, the platform must provide conspicuous disclosures. The law addresses the donation recipient, reasons a charity may not receive funds, maximum delivery time, fees or other amounts, and tax deductibility.

A platform or platform charity must obtain written consent before using a recipient charity's name in a solicitation. The consent can be provided by an authorized representative and can cover multiple expressly identified affiliated platforms.

Donations must not be diverted or misused and must be held separately from the platform's or platform charity's other funds. The law calls for prompt delivery and an accounting of processing fees, subject to the governing rules.

The platform must maintain a complaint process, investigate complaints, make findings, and report findings and resolution actions to the department on request. Vendor contracts involving solicitation, receipt, control, processing, distribution, or accounting must be available for inspection.

Which product and data changes should platforms plan?

AreaRequired decisionSystem evidence
RegistrationWhich entity files?Accepted registration
ConsentWho authorized use?Effective agreement
Good standingMay charity receive funds?Dated status check
DisclosureWhat did donor see?Versioned screen
FundsWhen was money sent?Ledger and payout

Source: Hawaii HB 1254 and Hawaii Attorney General portal. Reviewed September 24, 2026.

Consent needs a lifecycle state. The product should know when authorization begins, what uses it covers, when it expires or is revoked, and which pages, campaigns, recurring gifts, and assets are affected.

Good-standing checks should use the sources permitted by the law and the platform's approved policy. Save the organization identifier, source, lookup time, result, exception, reviewer, and later status before payout.

Preserve the disclosure version shown for each donation. A current webpage cannot prove what a donor saw before a later copy change.

Maintain campaign records for the required period. The statute specifies fields related to contributions, people involved, revenue, expenses, and financial accounts, with records available for Attorney General inspection.

Prepare for Hawaii platform compliance

Change helps charitable fundraising platforms manage nonprofit consent, eligibility, donations, payouts, records, and reporting.
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How is Hawaii different from California?

California permits a regulated pathway for some solicitations involving non-consenting charities. Hawaii's framework requires written consent before using a recipient charity's name in a solicitation.

Hawaii expressly requires a complaint process and specifies a three-year minimum for listed campaign records. It also includes contract-filing provisions for platforms and platform charities, subject to the law's third-party disbursement intermediary language.

California uses its own forms, deadlines, good-standing sources, disclosure rules, payout schedules, and platform charity notifications. Read the side-by-side California and Hawaii guide before building a combined workflow.

Use one control framework with jurisdiction-specific rules. Shared components can include entity data, charity identity, consent records, disclosures, ledgering, receipts, complaints, payouts, and reports, while each state retains its own configuration and evidence.

Change's charitable fundraising platform solution supports nonprofit consent, verification, donation records, payouts, and compliance workflows for online giving products.

How should teams operationalize these requirements?

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.

Frequently asked questions

When did Hawaii's platform law take effect?

The amended framework took effect July 1, 2026.

Does Hawaii require written nonprofit consent?

Yes. The law requires written consent before a platform or platform charity uses a recipient charity's name in a solicitation.

Must Hawaii platforms register?

A covered charitable fundraising platform must register before soliciting, permitting, or enabling solicitations and is subject to renewal and reporting requirements.

How long must campaign records be kept?

The statute identifies records that must be maintained during the campaign and for at least three years after it ends.

Can a California compliance program be reused?

Shared systems can be reused, but Hawaii needs its own classification, consent, filing, disclosure, good-standing, contract, record, complaint, and reporting rules.

This article provides general information, not legal advice. Consult qualified counsel about the platform's product, parties, users, and jurisdictions.

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