Charleston Principles: Multi-State Nonprofit Registration Rules

The Charleston Principles are a set of guidelines adopted on March 14, 2001, by the National Association of State Charity Officials (NASCO) that tell nonprofits when their online fundraising creates enough of a connection to a state to require registering there. About 40 states require charities to register before soliciting donations from their residents, and the Principles are the framework state regulators use to decide what counts as “soliciting” when a website is visible from everywhere at once.¹

The Principles are advisory, not law. No state is required to follow them, and they carry no independent legal force. But they’ve shaped how state attorneys general and charity regulators think about internet-based solicitation for over two decades, and no formal update has been issued since 2001. The core idea has held up: regulators care about whether your nonprofit has reached into their state to ask for money, and the Principles give them a structured way to answer that question regardless of whether you used a website, an email blast, or a social media campaign.

Home-State Registration Is Always Required

Every nonprofit must register in the state where it is domiciled, meaning the state where its principal place of business is located. The Principles are unambiguous on this point: home-state registration applies regardless of whether the nonprofit’s website is interactive, passive, or run by a third party. If you are incorporated in one state but operate out of another, the state where your office actually sits is the one that counts for domicile.¹

This baseline obligation exists even if your website does nothing more than describe your mission. Once you move beyond your home state, the analysis gets more nuanced.

When Another State’s Registration Is Triggered

For states where a nonprofit is not domiciled, the Principles lay out three scenarios that require registration.

The first is straightforward. If your offline work in a state (events, direct mail, phone calls) would independently require registration under that state’s existing law, you still have to register. The internet doesn’t erase pre-existing obligations.

The second applies when your website is interactive. An interactive site is one that lets a donor complete a transaction online: entering credit card information, authorizing an electronic funds transfer, or processing a payment through a linked service. A site with a “Donate Now” button that routes to a payment processor is interactive; a site that displays a mailing address is not. What matters is the technical capacity to process a gift, not whether anyone has actually used it. If your site is interactive, registration is required in another state when you either specifically target residents of that state or receive contributions from the state on a repeated and ongoing or substantial basis.¹

The third scenario covers non-interactive sites paired with offline follow-up. If your site invites visitors to mail a check, call to give, or take other offline steps to contribute, and you also make additional contact with the state (such as sending emails promoting the site), the same targeting and contribution-volume tests apply.

What Counts as Specifically Targeting a State

The Principles define “specifically targeting” broadly. Any express or implied reference to soliciting contributions from a particular state qualifies, as does affirmatively appealing to residents when you know or should know they are located there. In practice, this covers several common tactics.

Geo-targeted digital advertising to specific zip codes, cities, or states.
Fundraising emails or newsletters sent to people you know are located in a particular state, including follow-up emails responding to inquiries from state residents.
Localized website content, such as location-specific keywords, references to local events, or landing pages aimed at donors in a particular area.

The targeting analysis focuses on what the nonprofit does, not what donors do independently. If someone in a state you’ve never marketed to stumbles across your website and makes a gift, that single unsolicited donation doesn’t mean you targeted the state. But if you add that donor to a mailing list and start sending fundraising appeals, you have crossed the line.

What Counts as Repeated, Ongoing, or Substantial Contributions

Even without targeting a single state, an interactive website can trigger registration if you receive contributions from that state on a “repeated and ongoing basis” or on a “substantial basis.” The Principles define this as contributions of sufficient volume within a fiscal year to show a regular or significant pattern, as opposed to rare or isolated gifts.¹

Here the framework leaves the hard part to individual states. The Principles deliberately do not set specific dollar amounts or transaction counts, and there is no national threshold. Some states have published their own numerical standards; others have not. The Principles recommend that states publish clear numbers so nonprofits can self-assess, but adoption has been uneven. The practical consequence is that any nonprofit with an interactive website receiving regular donations from multiple states needs to track where its money is coming from and check each state’s specific rules.

Regular auditing of donation sources by state is the only reliable way to know when you have crossed a threshold. Waiting until a regulator contacts you is a losing strategy, because by then you have already been out of compliance, and some states impose penalties retroactively to when registration should have occurred.

Passive Sites and Locally Focused Charities

A nonprofit that maintains a purely informational website without interactive donation processing generally does not trigger out-of-state registration solely because the site is accessible nationwide. The Principles treat these sites as digital brochures. Posting a mission statement, annual reports, or program descriptions is not solicitation, even if someone reading the site decides to mail in a check.

Charities that operate on a local or limited geographic basis get additional protection. If your website makes clear in context that your fundraising focus is limited to a specific area, regulators generally will not treat you as targeting distant states, even if you occasionally receive a contribution from outside your operating area. The Principles note that this context can come from an express statement on the site or from the overall content making the local focus obvious.¹

The Principles considered requiring specific disclaimer language that would create a safe harbor, and rejected it. The concern was that mandating particular words could raise compelled-speech issues. Instead, regulators look at the substance of what the site communicates and whether it is genuinely reaching into their state.

Organizations relying on passive status should watch for feature creep. Adding a payment-processing widget, embedding a crowdfunding link, or integrating a third-party donation platform can convert a passive site into an interactive one overnight.

Crowdfunding and Third-Party Platforms

The Principles predate modern crowdfunding by nearly a decade, but their logic maps onto it cleanly. A campaign hosted on a platform like GoFundMe or a peer-to-peer giving day is designed to spread across geographic boundaries. When supporters share a fundraising link with friends and family in other states, the nonprofit’s solicitation has effectively entered those states, which can trigger registration wherever donors contribute, particularly when a state generates substantial or repeated contributions.

The nonprofit, not the platform, typically bears the registration obligation. The charity is the entity soliciting; the platform is the tool. Some states have begun requiring platforms themselves to register separately as charitable fundraising platforms, but that does not relieve the charity of its own duty. Paid professional fundraisers and consultants who run online campaigns on behalf of a charity face their own registration requirements in many states, so if you hire a firm to manage digital fundraising, both you and the firm may need to register separately.²

Consequences of Failing to Register

Operating without required registration exposes a nonprofit to escalating consequences. The specifics depend on the state, but the general progression is consistent.

Administrative fines vary significantly by state. Some states impose penalties per violation, meaning each solicitation sent or each day of noncompliance counts as a separate offense, and fines of several thousand dollars per violation are not uncommon.
A state attorney general can issue a cease-and-desist order requiring the organization to stop all fundraising directed at the state’s residents until it comes into compliance.
Repeated or willful noncompliance can cost an organization the right to solicit in the state entirely, which can take years to restore.
In cases involving intentional fraud or misuse of donated funds, regulators can seek court orders freezing assets and refer cases for criminal prosecution of the organization’s leadership.

Beyond formal penalties, operating without registration damages credibility. Donors increasingly check state charity registries before giving, and institutional funders often require proof of registration as a condition of grants.

Managing Compliance Across Many States

For a nonprofit with a national online presence, the compliance burden is real. Registering individually in 40 states, each with its own forms, fees, deadlines, and renewals, is a significant administrative undertaking. Registration fees range from nothing in some states to several hundred dollars, and annual renewals follow a similar spread, often on sliding scales tied to revenue. A mid-sized nonprofit soliciting nationally can spend thousands of dollars annually on registration fees alone, before accounting for staff time or outside help.

The Unified Registration Statement (URS) was created to simplify this by providing a single form accepted by multiple states. It remains available, but its usefulness has declined. Only about 18 states still accept it for initial registration, and just 13 accept it for renewals. Many states now require online filing through their own portals and no longer accept the URS at all.

Most states also require supporting documents alongside the registration form, including articles of incorporation, bylaws, the IRS determination letter, a list of officers and directors, and the organization’s most recent IRS Form 990. Keeping these current and readily available saves significant time during filing season.²

Registration is not a one-time task. Renewals, annual financial reports, and updated disclosure statements are ongoing obligations that persist as long as the organization solicits in a state. For nonprofits soliciting in more than a handful of states, outsourcing filings to a third-party compliance service is often more cost-effective than managing them internally.

1
National Association of State Charity Officials. Resources
2
Internal Revenue Service. Charitable Solicitation – State Requirements