Hawaii’s charitable fundraising platform law creates new compliance requirements for companies that enable online charitable giving, with key updates from HI SB 1048 and related HB 1254 legislation.
Hawaii is following California’s lead.
After California introduced AB 488, the first major state framework for charitable fundraising platforms, Hawaii passed its own version of online fundraising regulation through SB 1048. The law is scheduled to take effect on July 1, 2026.
For companies that run online donation programs, round-ups at checkout, customer-choice giving, charitable sales promotions, crowdfunding campaigns, or other digital fundraising experiences, this is a major development.
The goal is to protect donors, protect nonprofits, and create clearer rules for how charitable funds are solicited, received, held, reported, and distributed.
For companies, the operational implications are significant. Hawaii’s law introduces registration, annual renewal, written charity consent, donor disclosures, fund segregation, recordkeeping, and reporting obligations for charitable fundraising platforms.
If your business helps donors give to nonprofits online, now is the time to prepare.
HI SB 1048 amends Hawaii’s charitable solicitation laws to regulate charitable fundraising platforms and platform charities. It builds on Act 205, which Hawaii passed in 2024, and clarifies how online crowdfunding and platform-based charitable fundraising should be supervised by the Department of the Attorney General.
The law reflects a broader regulatory shift. Online giving is no longer limited to traditional nonprofit donation pages. Today, donations can flow through marketplaces, fintech apps, ecommerce checkouts, fundraising platforms, workplace giving tools, loyalty programs, sweepstakes, and social campaigns.
Older fundraising statutes were not built for this level of digital activity. Hawaii’s law is designed to bring more structure to that environment.
Under SB 1048, charitable fundraising platforms must register with the Department of the Attorney General before enabling charitable solicitations. Platforms must also provide donor disclosures, obtain written consent from recipient charities, hold charitable funds separately from platform funds, send donations promptly, maintain records, and operate a complaints process.
For companies, the message is clear. Digital fundraising is becoming a regulated product experience.
Hawaii defines a charitable fundraising platform broadly.
In practical terms, a company may qualify if it uses the internet to provide a website, service, app, or other platform to people in Hawaii and performs, permits, or otherwise enables charitable solicitations.
That can include companies that:
The definition is intentionally broad. A company does not need to look like a traditional fundraising platform to fall within the law’s scope.
A retailer running online checkout donations, a fintech app enabling charity round-ups, or a marketplace allowing customers to support selected nonprofits may all need to evaluate whether Hawaii’s charitable fundraising platform rules apply.
Hawaii’s law is part of a larger regulatory trend. California AB 488 created a new compliance category for charitable fundraising platforms, and Hawaii is now adopting a similar framework.
Both laws focus on the same core principles.
Donors should understand where their money is going. Nonprofits should know when their names are being used. Charitable funds should be handled separately from commercial funds. Platforms should be able to show regulators how donations were tracked, distributed, and reported.
That sounds simple. In practice, it requires infrastructure.
Companies need systems for nonprofit consent, donation tracking, payout timing, donor receipts, disclosures, accounting, and state reporting. These responsibilities often involve legal, product, finance, engineering, and social impact teams.
The companies that prepare early will be better positioned to keep campaigns running without interruption.
California and Hawaii share a similar policy goal, but the two laws are not identical.
California AB 488 is already live. Charitable fundraising platforms must register with the California Attorney General before performing, permitting, or enabling solicitations, and platform renewals are handled through the California DOJ’s online filing process.
Hawaii’s law takes effect July 1, 2026. The state has established the statutory framework, but companies are still waiting for additional guidance from the Hawaii Department of the Attorney General, including practical filing forms and implementation details.
The biggest differences companies should watch include written charity consent, contract filing, good standing checks, recordkeeping, complaints, and renewal timing.
| Requirement | CA AB 488 | HI SB 1048 |
|---|---|---|
| Register with AG before soliciting | ✅ Effective June 12, 2024 | ✅ Effective July 1, 2026 |
| Annual renewal & report | ✅ Renewal due Jan 15; report due July 15 | ✅ Required; dates TBD by AG |
| Online filing system | ✅ Required via AG's Online Filing Service | 🔲 Forms not yet published |
| Good standing verification | ✅ Must check IRS, FTB, and CA AG, all three; 5-day grace period if charity lapses | ✅ AG registry only; grace period TBD |
| Written charity consent | ✅ Required, but exceptions exist for open-catalog platforms | ✅ Required, no exceptions |
| File contract with AG | ⚠️ Not explicitly required | ✅ Required before any fundraising activity |
| Donor disclosure: who receives funds | ✅ | ✅ |
| Donor disclosure: fees, timing, tax deductibility | ✅ | ✅ |
| Donor disclosure: why charity might not receive funds | ✅ If platform has such a policy | ✅ |
| Segregate donated funds from platform's own funds | ✅ | ✅ |
| Distribute donations promptly with fee accounting | ✅ Specific timelines by solicitation type (5-45 days depending on type) | ✅ “Promptly”, timeline TBD by AG |
| Donor tax receipt | ✅ Within 5 business days (Types A/B) | ✅ “Promptly”, timeline TBD |
| Maintain records for AG inspection | ✅ | ✅ 3-year minimum; more fields specified than CA |
| Formal complaints process | ⚠️ Not explicitly required | ✅ Must maintain, investigate, and report to AG on request |
| Notify AG of platform charity partnerships | ✅ Form PL-3 within 30 days | ❌ Not required |
The table above highlights a few important themes.
First, Hawaii appears to take a stricter approach to written charity consent. California requires written consent in many circumstances, but also includes exceptions for certain open-catalog platform models. Hawaii’s law requires written consent before using a recipient charity’s name in a solicitation.
Second, Hawaii includes a contract filing requirement before fundraising activity begins. This may create additional lead time for campaign launches.
Third, Hawaii’s law includes a formal complaints process. Platforms must maintain a process for complaints about covered fundraising activity, investigate those complaints, and report findings to the Department of the Attorney General upon request.
Fourth, Hawaii’s filing mechanics are still developing. Companies should not wait for final forms before beginning compliance planning.
While further guidance is expected, SB 1048 outlines several major obligations for companies that qualify as charitable fundraising platforms.
A charitable fundraising platform must register with the Hawaii Department of the Attorney General before soliciting, permitting, or otherwise enabling charitable solicitations.
This means registration should be treated as a pre-launch requirement, not an after-the-fact filing.
Platforms must renew their registration annually. Hawaii’s law also requires reporting that allows the Department to understand how charitable funds were solicited, received, held, controlled, or distributed.
Reports may include donation volume, amounts raised, fees, payout timing, and recipient charities that did or did not receive funds.
Platforms must obtain written consent from a recipient charitable organization before using that organization’s name in a solicitation.
This is one of the most important operational requirements. If your platform supports hundreds or thousands of nonprofits, consent cannot be managed casually through email threads and spreadsheets. It needs to be structured, trackable, and current.
Before a person completes a donation or selects a recipient charity, the platform must provide conspicuous disclosures designed to reduce confusion.
These disclosures may need to explain who receives the donation, why a charity may not receive funds, how long distribution may take, what fees may be deducted or added, and whether the donation is tax deductible.
Platforms must hold charitable donations in a separate account or accounts from their own funds.
This requirement directly affects finance and payment operations. Companies should review how funds are collected, where they settle, how fees are deducted, and how donations are reconciled.
Platforms must ensure donations or grants of recommended donations are sent promptly to recipient charities, with an accounting of fees assessed for processing the funds.
Additional guidance may clarify what “promptly” means in practice. We're still waiting to hear from the state for that guidance.
Platforms must maintain records for inspection by the Attorney General. Hawaii also requires platforms to operate a complaint process, investigate complaints, and report findings to the Department upon request.
These obligations make documentation essential. Companies should be able to show what was promised, what was collected, what was withheld, what was distributed, and when each step occurred.
Companies that may qualify as charitable fundraising platforms should begin preparing now, even while final implementation details are still pending.
Start by identifying every place your product enables charitable giving. Include checkout donations, round-ups, cause marketing campaigns, peer-to-peer flows, customer-choice catalogs, employee giving tools, and any experience where a user can select or support a nonprofit.
Once those flows are mapped, determine where Hawaii residents may interact with them.
Create a clear inventory of recipient charities, campaign beneficiaries, and nonprofit partners. For each organization, document its legal name, EIN, campaign role, consent status, and current eligibility.
If your company maintains a large nonprofit catalog, this step is especially important.
Hawaii’s consent requirement should be treated as a core compliance workflow.
Companies need a reliable way to collect, store, update, and prove written consent from nonprofits. The consent process should identify who approved participation, what the nonprofit approved, which affiliated platforms or campaigns are covered, and when the approval was granted.
Disclosures should be clear, conspicuous, and built into the giving flow. Legal, product, and design teams should work together so disclosures are accurate without disrupting the user experience.
Key questions include: Who receives the donation? Are fees deducted? When will funds be sent? Is the gift tax deductible? Are there any circumstances where the selected nonprofit may not receive the funds?
Finance and payments teams should confirm where charitable funds settle, whether those funds are separated from operating funds, and how disbursements are tracked.
If charitable funds are mixed with commercial revenue, that model may need to be restructured before the law takes effect.
Hawaii’s law requires platforms to maintain records and provide information to the Department of the Attorney General. Companies should avoid relying on manual reconciliation after campaigns end.
A scalable system should track donation amount, donor-facing campaign terms, recipient charity, fees, payout timing, tax receipt status, and complaint history.
Hawaii has set the effective date, but practical filing forms and further implementation guidance are still expected. Companies should monitor updates from the Department of the Attorney General and prepare internal systems now so they can act quickly once forms are available.
California AB 488 is already in effect.
If your company enables charitable giving online and reaches California donors, you may already be required to register as a charitable fundraising platform with the California Attorney General. California also requires annual renewal, donor disclosures, charity good standing checks, disbursement timing controls, donor receipts, reporting, and written nonprofit consent in many circumstances.
For companies preparing for Hawaii, California is the best preview of what platform compliance looks like in practice.
The operational lesson has been proven – these laws are best handled with ongoing systems that can keep up with the demand of nonprofit verification and consent, and flexibly adapt as regulations change.
A company needs to know which nonprofits are eligible, which have provided consent, which campaigns are live, what disclosures were shown, how donations were processed, when funds were distributed, and what records must be retained. That is platform compliance.
Change helps companies run charitable campaigns with the infrastructure needed to support modern compliance requirements. For charitable fundraising platforms, Change can support:
As Hawaii’s law comes into effect, companies will need more than awareness. They will need operational readiness. Change helps teams move from legal analysis to implementation.
See How Change Supports Platform Compliance
Hawaii SB 1048 takes effect on July 1, 2026.
Hawaii HB 1254 and SB 1048 addressed similar updates to Act 205, Hawaii’s charitable fundraising platform law. SB 1048 is the version most commonly referenced in connection with the amended framework taking effect July 1, 2026, while HB 1254 is still relevant for those searching the legislative history or tracking related House-side amendments.
As of now, companies are still waiting for additional filing guidance and forms from the Hawaii Department of the Attorney General.
No. The law focuses on platforms that provide online charitable fundraising services to persons in Hawaii. Companies outside Hawaii should evaluate whether their donation experiences reach Hawaii users or donors.
The laws are similar, but they differ in important ways. Hawaii requires written charity consent and includes additional obligations around contract filing, complaints, and recordkeeping. California has its own registration process, renewal deadlines, good standing framework, and solicitation-type rules.
Companies that offer online donations, checkout giving, customer-choice giving, crowdfunding, peer-to-peer fundraising, round-ups, charitable sales promotions, or platform-based nonprofit support should evaluate the law.
Hawaii’s charitable fundraising platform law is scheduled to take effect on July 1, 2026. The state has not yet published every practical detail companies will need to file and operate under the new framework, but the direction is clear.
Online charitable fundraising is becoming more regulated.
Companies that begin mapping donation flows, collecting nonprofit consent, tightening disclosures, separating funds, and preparing reporting systems now will be better positioned when Hawaii’s filing process becomes available. Change helps companies build that foundation.
Note: Hawaii’s charitable fundraising platform rules are most commonly discussed through SB 1048, which amended Act 205 and is scheduled to take effect on July 1, 2026. Related House-side legislation, including HB 1254, addressed similar amendments to Hawaii’s platform fundraising framework, which is why you may see both bill numbers referenced in searches and legislative trackers.
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