What Nonprofits Need to Know
Nonprofits that engage professional fundraisers, solicitors, fundraising counsel, or commercial co-venture partners face additional charitable solicitation registration and disclosure requirements beyond those that apply to organizations fundraising solely through staff or volunteers.
These requirements vary significantly by state and are a common source of compliance gaps—particularly for organizations fundraising nationally.
If your organization works with paid fundraising partners and wants to confirm its registration posture, Ironwood Registrations can help evaluate your compliance obligations: contact us
Who Is Considered a Professional Fundraiser or Solicitor?
State laws use different terminology, but regulated fundraising partners typically include:
- Professional solicitors – entities or individuals who directly solicit donations for compensation
- Fundraising counsel or consultants – advisors who plan or manage campaigns but may not directly solicit
- Commercial co-venturers – for-profit entities that advertise a charitable promotion tied to sales
- Paid peer-to-peer fundraising vendors (in certain structures)
Importantly, the nonprofit remains responsible for ensuring that required registrations and disclosures are in place.
Why Using Paid Fundraisers Changes Registration Obligations
When a nonprofit uses professional fundraisers, states may require:
- Separate registration of the fundraiser
- Filing of fundraising contracts
- Pre-approval or review of solicitation materials
- Additional disclosures in donor communications
- Campaign-specific financial reporting
These requirements are often in addition to the charity’s own registration.
Common Misconceptions
“Our fundraiser handles registration.”
While fundraisers may register themselves, the charity must still ensure compliance. States routinely hold the nonprofit accountable for missing or incomplete filings.
“Fundraising counsel doesn’t trigger extra requirements.”
In many states, fundraising counsel arrangements still require contract filing or disclosure, even if the consultant does not directly solicit donations.
“This only matters in one or two states.”
Professional fundraiser regulation exists in many states, and requirements vary widely. Multi-state campaigns often trigger obligations in numerous jurisdictions simultaneously.
Typical State-Level Requirements When Using Fundraisers
Depending on the state, nonprofits may be required to:
- Register or renew their own charitable registration
- Ensure the fundraiser is properly registered
- File copies of fundraising contracts before campaigns begin
- Disclose compensation structures
- Submit post-campaign financial reports
- Update registrations when fundraiser relationships change
Failure to complete any of these steps can delay campaigns or result in compliance findings.
Timing Matters: Before the Campaign Begins
Many states require advance filing of fundraiser contracts or registrations before solicitation starts.
This is especially important for:
- National campaigns
- Time-sensitive appeals
- Online or digital fundraising launches
- Commercial promotions tied to product sales
Late filings often cannot be retroactively cured without penalties.
Online and Platform-Based Fundraising Complications
When professional fundraisers are involved in online fundraising:
- Donation platforms do not eliminate fundraiser disclosure requirements
- Digital campaigns may trigger registration in additional states
- Recurring or peer-to-peer programs increase reporting complexity
Fundraiser involvement often expands multi-state exposure more quickly than anticipated.
Related guidance: Online donation platforms and charitable registration
Financial Reporting and Audit Considerations
Use of professional fundraisers may affect:
- How contributions are reported
- What financial disclosures are required
- Whether additional schedules or reports must be filed
- Audit scrutiny of fundraising expenses and ratios
For organizations exceeding ~$500,000 in contributions, these issues frequently intersect with audit and renewal timing.
Why These Issues Often Surface Late
Nonprofits frequently discover fundraiser-related registration gaps during:
- Audits
- Grant or foundation due diligence
- Regulator inquiries
- Contract renewals with fundraising vendors
- Board or governance reviews
At that point, remediation is more complex and disruptive.
Best Practices for Nonprofits Using Fundraisers
Organizations that work with paid fundraisers typically benefit from:
- Reviewing registration implications before signing contracts
- Coordinating fundraiser and charity filings together
- Aligning campaign launches with filing timelines
- Tracking fundraiser relationships by state
- Maintaining centralized documentation
This is particularly important for organizations running national or multi-state campaigns.
Multi-state compliance overview
How Ironwood Registrations Helps
Ironwood Registrations works with nonprofits to:
- Identify fundraiser-related registration requirements by state
- Coordinate charity and fundraiser filings
- Manage contract submissions and disclosures
- Align campaign timing with compliance obligations
- Reduce risk during audits and regulatory reviews
Schedule a consultation if your organization uses professional fundraisers or solicitors: Schedule consultation
Or contact our team directly
Related Resources
Charitable Solicitation Registration Requirements by State
Charitable Solicitation Registration Mistakes That Put Nonprofits at Risk