Asking for money across state lines: charitable solicitation registration

What counts as soliciting

State charity laws regulate the request for a gift. As the state charity officials who wrote the Charleston Principles put it, "our laws require registration when somebody asks for money, whether or not anybody gives them any" (Charleston Principles, annotation to Principle I(D)).

That makes most fundraising channels a solicitation: mailed letters, emails, phone calls, events, a donation page, a social post with a giving link, and a video that asks viewers to give. The usual trigger for registration is soliciting people in a state, not being located there.

Registration is separate from your federal tax exemption. A 501(c)(3) determination letter doesn't register you with any state, though some states use it to grant an exemption.

Which states require registration

The National Association of State Charity Officials (NASCO) publishes a state survey. As of its Summer 2026 data, cross-checked with compliance providers' 2026 lists, the picture is roughly this:

Registration is generally required before the first ask, not after the gifts arrive. North Dakota's Secretary of State, for example, says a charitable organization "cannot operate and solicit contributions until the registration has been approved and is on file" (ND Secretary of State).

Common exemptions

Most states exempt some organizations, but the categories and limits differ. A few verified examples:

• Religious organizations. Missouri exempts "religious organizations" (RSMo 407.456). North Dakota exempts a religious organization that is exempt from filing a federal annual information return (ND Secretary of State). Virginia excludes churches and conventions or associations of churches (Va. Code § 57-60). Mississippi excludes religious institutions only if they are tax exempt and primarily supported by their own members, congregations, fees or government funds (Mississippi Charities Act). A ministry that raises money widely from the public may not fit a state's religious exemption.
• Small, volunteer-run groups. Virginia exempts groups that raise no more than $5,000 a year from the public and use only unpaid volunteers, and requires registration within 30 days once contributions pass $5,000 (Va. Code § 57-60). Mississippi has a similar rule at $25,000 (Mississippi Charities Act). Florida doesn't exempt small groups but lets those under $50,000 in contributions, with no paid fundraisers, file a simpler application with no fee (FDACS).
• Schools. Missouri exempts educational institutions and their foundations (RSMo 407.456). North Dakota exempts certain organizations soliciting for schools and institutions of higher learning.
• Exempt isn't the same as unregulated. Florida requires the organizations it exempts under § 496.406(1)(d) to print its disclosure statement anyway (Fla. Stat. § 496.411(3)), and fraud laws apply to everyone.

Donation pages, email and the Charleston Principles

In 2001 NASCO's board approved the Charleston Principles as "advisory guidelines" for applying state laws to internet fundraising. They are not law, and they say plainly that state laws vary and that applying the principles may vary too. They remain the standard reference.

In short, the principles say:

• Your home state. A charity whose principal place of business is in a state and solicits there online must register there.
• Other states, interactive sites. If your site lets people give online, register in another state if you specifically target people there, or if you receive gifts from there "on a repeated and ongoing basis or a substantial basis" through the site. Targeting includes a site that refers to soliciting that state, and advertising or sending messages to people you know, or should know, are there.
• Other states, non-interactive sites. A page that only gives a mailing address or phone number can still count if you also send email or other messages promoting it, and the same targeting or volume test is met.
• Email into a state is treated like mail or phone solicitation if you knew or reasonably should have known where the recipient is. The annotations note that a past online donor's billing address tells you where they live.
• Volume. States are asked to set their own numbers. The principles give, only as an example, 100 online contributions or $25,000 in a year.
• Local charities. A charity whose site makes clear it raises money only in its local area isn't treated as targeting other states, unless gifts from elsewhere become repeated and ongoing or substantial.
• Information-only sites that don't ask for gifts don't trigger registration, even if someone sends a gift anyway. Payment processors and web hosts that only provide technical services don't register, but the charity still has to.
• If you would have to register in a state because of mail, phone or in-person asks, the internet rules don't change that.

What this means for emails, videos and social posts

• An appeal email to your list is a solicitation in every state where you know, or should know, recipients live. Past donors' addresses usually tell you.
• A social post or video with a "give" link sends people to an interactive giving page. Under the Charleston approach, a targeted campaign, such as ads aimed at one state, can require registration there.
• A thank-you or impact video with no ask is not usually a solicitation. Add "give today" and it becomes one.
• Several disclosure laws reach beyond the first appeal to confirmations, receipts and reminders, and Florida's reaches web pages that take gifts. See the table below.
• Track gifts by state each year, so you can see when a state's volume threshold may apply.

Filing: the Unified Registration Statement and the single portal

Unified Registration Statement (URS). The URS is a paper form, organized by NASCO and the National Association of Attorneys General, that some states accept in place of their own registration form. Its maintainer, the Multi-State Filer Project, now says it "has limited utility today since most states require online filing." As of June 2025 it listed Arkansas, Georgia, Illinois, Kansas, Minnesota, Oregon and Virginia as accepting the URS, with Hawaii requiring the URS to be filed online and New Mexico accepting it only from organizations exempted from electronic filing (Multi-State Filer Project). The URS has never been approved for annual renewals or financial reports.

Single portal. The Multistate Registration and Filing Portal (MRFP) was set up to let charities file with many states in one place. On October 6, 2026, the portal's filing page listed only two states, Georgia and Connecticut, the same two it launched with. For every other state, file with that state's own system.

Renewals and financial reports

Registration is rarely one-and-done. Most states require an annual renewal, usually due a set number of months after your fiscal year ends, with a financial report. Many accept or require a copy of your IRS Form 990. Larger organizations may need financial statements reviewed or audited by a CPA, at thresholds that differ by state. Oregon, for example, registers once and then requires annual reports, and North Dakota's annual report is due by September 1 (NASCO survey; ND Secretary of State).

Missing a renewal can mean you are soliciting while unregistered. Put every state's due date on one calendar, keyed to your fiscal year end and your Form 990 filing.

Professional fundraisers and fundraising counsel

Many states also register the people you pay to raise money. The names vary, but usually there are professional solicitors (or fundraisers), who ask for gifts or handle the money, and fundraising counsel (or consultants), who plan and advise but don't solicit or hold funds. Pennsylvania alone lists more than 450 registered professional solicitors and fundraising counsel (Pennsylvania Department of State).

The duty can fall on the charity too. Florida bars a charity from contracting with a professional solicitor or fundraising consultant that isn't registered with the state (Fla. Stat. § 496.411(5)). Washington and Mississippi require extra disclosures when a paid fundraiser makes the ask, and Georgia requires a paid solicitor to say its contract with the charity is on file with the Secretary of State.

Software and service vendors are a gray area. The Charleston Principles say providers of purely technical services don't have to register, but one that writes content, drives traffic to your appeal or is paid a share of what is raised may be doing more than technical work.

Disclosure statements on written appeals

Some states require set wording on solicitations, and often on receipts and reminders too. These are the ones verified against the statute, regulation or state office page. Bracketed text is filled in by you. Check current phone numbers and web addresses with each state before printing.

Many national charities print one combined block with each state's statement, often in the footer of letters, emails and donation pages. If you do, keep each state's wording exactly as required, and update it when a phone number or web address changes.

When an AI drafts the appeal, or a video ends with "give"

None of these laws care who wrote the appeal. A fundraising email drafted by an AI assistant, a deck that closes with a giving slide, or a video that ends with a "give" button is your solicitation, and your registrations and disclosures apply to it exactly as they would to a letter your development director wrote.

Two habits cover most of it. First, put your required disclosure block into the templates you use for appeals, receipts, reminders and donation pages, so it's there by default. Second, have a person check each appeal before it goes out: is the ask accurate, is the disclosure there, and are you registered in the states you are sending to?

• Don't let a draft promise anything you can't back up, like how a gift will be used or that it is matched.
• Make sure any video or share page that asks for gifts links to a donation page that carries your disclosures.
• If a vendor is paid a percentage of what is raised, ask whether it has to register as a professional fundraiser.

A checklist

• List every state where you solicit: by mail, email, phone, events, targeted ads or social campaigns. Include states where past donors live if you email them.
• Check each state's rules and exemptions on its charity office website, or with NASCO's state survey as a starting point.
• Register before you ask, or file for an exemption where the state requires one.
• Put every renewal and financial report date on one calendar, tied to your fiscal year end and Form 990.
• Add the required disclosure statements to letter, email, receipt and donation-page templates.
• Make sure any paid fundraiser or fundraising counsel is registered where required, and keep a written contract.
• Track gifts by state each year.
• Review every appeal before it is sent, whoever or whatever drafted it.
• When in doubt, ask the state office or a lawyer who works with charities.