California amends its online-giving platform law so fewer charities are cut off from donations
AB 2221, signed September 27, removes IRS revocation from "good standing," adds notice-and-cure steps and lets platforms set a $10 forwarding minimum.
By The Editors · The Game of Giving
California has amended AB 488, its 2021 law regulating online charitable fundraising platforms. The amending bill, AB 2221 by Assemblymember Jacqui Irwin, was signed by the governor and chaptered on September 27 as Chapter 590 of the Statutes of 2026. It changes how a charity's "good standing" is defined and gives registrants more time to fix filing problems, attorney Karen I. Wu of Perlman & Perlman wrote in The NonProfit Times on October 12.
Wu wrote that AB 488 led to thousands of charities, in California and elsewhere, losing access to online donations because platforms could send money only to charities in good standing. Most of the filing problems, she wrote, were minor and administrative, and resolving them took months because of agency backlogs.
What changes
The amendments remove IRS revocation from the definition of good standing, according to Wu's summary. A charity can still fall out of good standing if the Attorney General has issued a cease-and-desist order or if its registration is delinquent, suspended or revoked. Before a registration is declared delinquent, the Attorney General must send a deficiency notice with 60 days to respond, then further notices; the law firm Adler & Colvin describes two 60-day cure periods before a third notice declares delinquency.
Platforms handling individual donations through websites or apps, including peer-to-peer campaigns, may set a minimum of up to $10 before forwarding funds, if it is disclosed, Wu wrote. All funds must still be sent within 12 months of the donation. Where the intended charity cannot receive a gift, platforms have other options, including refunds of donations of $10 or less in some cases.
Later start dates
A new or resolved registration will be treated as in good standing if the Attorney General has not processed it within 15 days, beginning January 1, 2028, Wu wrote. By that date the Attorney General's online filing system must support comprehensive electronic administration, a requirement that also appears in the chaptered text. Adler & Colvin, in a September 30 update, said the final bill delays the good-standing and related provisions to January 1, 2028, and lets platforms again rely on electronic good-standing lists published by the Franchise Tax Board or the Attorney General.
Retail checkout campaigns are allowed only for charities that have given written consent, Wu wrote, and the earlier consent exception is eliminated. Wu's firm is a member of the Giving Platform Collaborative, which she credited with advocacy on the bill along with the California Association of Nonprofits.
What nonprofits should check
In our view, the immediate step is not a new filing but a status check. A charity that raises money through online platforms, in California or elsewhere, can confirm that its registration and annual reports with the Attorney General are current, since delinquency remains grounds for losing good standing. For a related look at the cost of missed paperwork, see three missed filings.
General information for donors and nonprofit leaders, not legal or tax advice. How we report is set out in our editorial guide.