Overview
As online fundraising has become central to nonprofit operations, one of the most common compliance questions is whether simply having a website or accepting online donations creates charitable solicitation registration obligations in multiple states.
The Charleston Principles were developed to help regulators interpret how traditional charitable solicitation laws apply to internet fundraising. While they are not statutes themselves, most state regulators rely on these principles when determining whether an organization must register before soliciting donations from residents of a state.
Understanding how the Charleston Principles work helps nonprofits evaluate when online activity creates multi-state compliance obligations — and when it does not.
Note: not all states follow the Charleston Principles. A table of which do is below.
What Are the Charleston Principles?
The Charleston Principles were issued in 2001 by the National Association of State Charity Officials (NASCO) to address a growing challenge: charities could suddenly reach donors nationwide through websites and email campaigns, even if their operations were local.
The principles establish a practical framework for distinguishing between:
- Passive online presence, which generally does not require registration everywhere, and
- Targeted or repeated solicitation, which may trigger registration requirements in additional states.
Although each state ultimately applies its own laws, regulators commonly use this framework when evaluating online fundraising activity.
Passive vs. Active Online Solicitation
A key concept within the Charleston Principles is whether fundraising activity is considered passive or actively directed toward residents of a state.
Passive Solicitation (Generally Not Enough Alone)
Examples include:
- Maintaining a website accessible nationwide
- Posting general information about programs or mission
- Accepting donations through a standard online donation form without targeting specific states
Simply being visible on the internet does not automatically require nationwide registration.
Active or Targeted Solicitation (May Trigger Registration)
Registration obligations are more likely when a nonprofit:
- Sends targeted email campaigns to residents of a specific state
- Runs geographically targeted digital advertising
- Conducts repeated or ongoing outreach into a jurisdiction
- Develops sustained donor relationships within a state
When outreach moves beyond passive availability and becomes intentional or repeated engagement, regulators may view the activity as solicitation within that state.
The “Repeated and Ongoing” Standard
One of the most important elements of the Charleston Principles is the concept of repeated and ongoing contacts.
Even without explicit targeting, registration may be expected when:
- Donations are received repeatedly from residents of a state, and
- The organization continues interacting with those donors through communications, acknowledgments, or future appeals.
In practice, this means organizations can unintentionally expand their compliance footprint as fundraising grows.
Why Online Fundraising Often Expands Registration Requirements
Modern fundraising tools make multi-state solicitation easy to create unintentionally:
- Online donation platforms accept contributions nationwide
- Social media campaigns reach audiences across jurisdictions
- Email newsletters circulate far beyond an organization’s home state
- Peer-to-peer fundraising spreads organically through donor networks
Because charitable solicitation laws regulate the act of asking, not just receiving donations, compliance obligations may arise earlier than expected.
Common Misunderstandings
“We only registered where we are located.”
Physical location is not the determining factor. Soliciting residents of another state can create registration obligations there.
“We didn’t target those donors.”
Repeated donations combined with ongoing communications may still trigger registration expectations.
“Online donations don’t count as solicitation.”
Most regulators treat online appeals the same as traditional fundraising requests.
Practical Compliance Approach
Nonprofits do not necessarily need to immediately register nationwide simply because they accept online donations. Instead, organizations should periodically assess their fundraising activity using a structured approach:
- Review where donations are originating.
- Evaluate whether outreach is targeted or repeated.
- Monitor growth in new donor states.
- Plan registration expansion before launching national campaigns.
- Document internal compliance reviews.
Early planning helps avoid situations where registration gaps are discovered during audits, grant applications, or regulator inquiries.
Which States Follow the Charleston Principles
Below is a table of which states follow the Charleston Principles and which do not. Those that do not follow the Charleston Principles typically have stricter guidelines for when registration obligations begin.
| State / Jurisdiction | Stance on Charleston Principles |
|---|---|
| Alabama | Does Not Follow |
| Alaska | Follows as Internal Policy |
| Arizona | N/A (No general registration required; only veterans charities) |
| Arkansas | Does Not Follow |
| California | Does Not Follow |
| Colorado | Adopted (Enacted into law) |
| Connecticut | Follows as Internal Policy |
| Delaware | N/A (No general registration required) |
| District of Columbia | Does Not Follow |
| Florida | Does Not Follow |
| Georgia | Does Not Follow |
| Hawaii | Follows as Internal Policy |
| Idaho | N/A (No general registration required) |
| Illinois | Does Not Follow |
| Indiana | N/A (No general registration required) |
| Iowa | N/A (No general registration required) |
| Kansas | Does Not Follow |
| Kentucky | Follows as Internal Policy |
| Louisiana | Does Not Follow |
| Maine | Does Not Follow |
| Maryland | Follows as Internal Policy |
| Massachusetts | Follows as Internal Policy |
| Michigan | Follows as Internal Policy |
| Minnesota | Follows as Internal Policy |
| Mississippi | Adopted (Enacted into law) |
| Missouri | Follows as Internal Policy |
| Montana | N/A (No general registration required) |
| Nebraska | N/A (No general registration required) |
| Nevada | Does Not Follow |
| New Hampshire | Follows as Internal Policy |
| New Jersey | Follows as Internal Policy |
| New Mexico | Follows as Internal Policy |
| New York | Does Not Follow |
| North Carolina | Follows as Internal Policy |
| North Dakota | Does Not Follow |
| Ohio | Does Not Follow |
| Oklahoma | Does Not Follow |
| Oregon | Follows as Internal Policy |
| Pennsylvania | Follows as Internal Policy |
| Rhode Island | Does Not Follow |
| South Carolina | Follows as Internal Policy |
| South Dakota | N/A (No general registration required) |
| Tennessee | Adopted (Enacted into law) |
| Texas | N/A (Limited registration for public safety, law enforcement, and veterans causes) |
| Utah | N/A (No general registration required effective 5/1/2024) |
| Vermont | N/A (No registration required for charities; only paid fundraisers) |
| Virginia | Follows as Internal Policy |
| Washington | Follows as Internal Policy |
| West Virginia | Follows as Internal Policy |
| Wisconsin | Follows as Internal Policy |
| Wyoming | N/A (No general registration required) |
How Regulators Typically Apply the Principles
In practice, regulators focus less on technical website access and more on overall fundraising behavior. They look at patterns such as:
- Intentional outreach into a state
- Frequency of donor interaction
- Evidence of ongoing solicitation activity
- Scale and consistency of fundraising efforts
This practical interpretation means compliance obligations often evolve gradually as organizations grow.
Key Takeaway
The Charleston Principles do not require nonprofits to register everywhere simply because they have a website. However, they do establish that online fundraising can create registration obligations once solicitation becomes targeted, repeated, or sustained within a state.
For organizations expanding fundraising nationally, understanding these principles allows compliance planning to occur before regulatory issues arise.