(image from afpglobal.org)
Guidelines and considerations for use of online fundraising platforms was recently issued by the Association of Fundraising Professionals (AFP) given recent controversy concerning the bankruptcy of platform Flipcause and the attorneys general in 23 states demanding information from GoFundMe after it established and then discontinued webpages on that platform without notifying the charities.
The guidelines include five areas: Fee Transparency; Discoverability and Public Data; Responsible Data Use; Responsible Fund Management; and, Resolution and Accountability.
According to a statement from AFP, the considerations “exist because the relationship between donors, nonprofits, and the platforms that connect them is not always well understood — and that misunderstanding can cause real harm. Donors may not realize they are transacting with an independent platform rather than directly with a nonprofit. Nonprofits may not know that donations are being collected on their behalf. Funds may be delayed, reduced by undisclosed fees, or in rare cases lost entirely when platforms fail.”
The considerations apply to any technology service through which charitable donations flow, whether that is the platform’s primary purpose or an incidental feature. This includes dedicated fundraising platforms, cause-discovery tools, payment processors with charitable giving features, donor-advised fund platforms, and any other service that collects, holds, or transmits funds intended for nonprofit organizations, according to the statement, released during the AFP’s recent international conference in San Diego.
The considerations represent a starting point, not a final word, said H. Art Taylor, president & CEO of AFP. The intent is to “give platforms something concrete to respond to — to agree with, push back on, and refine,” according to Taylor. To provide your feedback, submit comments via this form.
The following are the considerations and guidelines released by AFP.
Definitions
The following definitions apply throughout this document. They are offered as working terms to establish a shared framework for discussion, not as settled or field-wide consensus definitions, and are subject to additions, clarification, and revision as these considerations develop.
Platform: Any technology service that enables donors to make charitable donations, whether that is the platform’s primary purpose or an incidental feature.
For-profit platform: A technology company that processes charitable donations as a commercial service.
Nonprofit platform: A nonprofit organization that itself operates a giving platform as part of its mission, where the platform is the legal recipient of donated funds and regrants them to designated nonprofits. This includes donor-advised fund platforms and community foundations with online giving programs.
Hybrid platform: A for-profit entity that operates under a nonprofit fiscal sponsor or donor-advised fund arrangement, where the for-profit entity manages the technology and user experience while a nonprofit entity legally holds donated funds.
Fiscal sponsorship: An arrangement in which an established nonprofit organization extends its tax-exempt status to another project or entity, legally receiving donations on its behalf and taking fiduciary responsibility for ensuring funds are used for charitable purposes. In the platform context, this structure may allow a for-profit technology company to receive charitable donations through a nonprofit sponsor. Donors receive a valid tax deduction but should understand that their gift is legally made to the fiscal sponsor, not directly to the intended nonprofit or the platform.
Nonprofit: Any IRS-registered nonprofit organization eligible to receive tax-deductible contributions.
Donation pathway: The basic ability to donate to a nonprofit through a platform, based on publicly available IRS data, without the nonprofit having created an active presence on the platform.
Campaign: A fundraising presence that a nonprofit or a third party has actively created on a platform, with content, imagery, and public visibility beyond a basic donation pathway.
Third-party campaign: A campaign created by an individual or organization other than the nonprofit itself. This includes peer-to-peer fundraising campaigns initiated by supporters on behalf of a nonprofit, as well as donor-advised fund distributions directed to a nonprofit through a platform.
Charitable funds: Any funds collected by a platform on behalf of or for the benefit of a nonprofit, from the moment of donor transaction until disbursement to the nonprofit.
Platform Structure and Legal Status
Not all platforms are the same, and donors and nonprofits deserve to understand the differences. Some platforms are for-profit technology companies. Others are themselves nonprofit organizations — donor-advised fund sponsors, or community foundations — that operate giving platforms as part of their mission. A third category operates as a hybrid: a for-profit company managing the platform experience under a nonprofit fiscal sponsor or DAF arrangement.
These structural differences have real consequences. In some nonprofit and hybrid platform structures, donated funds are legally received by the platform organization itself — meaning the donor has made a completed charitable gift to the platform, and the subsequent transfer to the named nonprofit is technically a grant made at the platform’s discretion rather than a legal obligation. Most platforms honor donor intent, but donors and nonprofits should understand when this legal structure applies.
These considerations call on all platforms to disclose their structure clearly so that donors and nonprofits can make informed decisions about the platforms they use.
The Considerations
Consideration 1 — Fee Transparency
For donors: Donors are entitled to clear, specific, and plain-language disclosure of all fees associated with their transaction. Fee disclosures should be conspicuous and accessible, not buried in footnotes or obscured by complex language. When donors agree to terms of service, those terms should clearly identify who receives each fee and for what purpose, so that donors can make informed decisions before completing their gift.
For nonprofits: Where a nonprofit accesses or uses a platform, the same principles of transparency apply. Fee disclosures should be clear, specific, and in plain language, covering all applicable fees, including those the platform controls and, where known, those set by third parties such as payment processors.
Consideration 2 — Discoverability and Public Data
Donors should be able to find, give to, and raise funds for any IRS-registered nonprofit through a platform. To support this, platforms may draw on publicly available data, including IRS filings and Form 990 data, to ensure nonprofits are discoverable.
Platforms must clearly disclose to donors whether information displayed about a nonprofit has been provided by the nonprofit or drawn from publicly available data sources.
Nonprofits must have access to a simple, clearly communicated mechanism to append, update, or correct information displayed about them. This process should not require legal review, technical expertise, or significant staff time. Where a nonprofit has provided updated information, platforms should reflect that promptly.
Platforms may not use a nonprofit’s intellectual property assets, including logos and trademarked imagery, beyond basic nonprofit identification without prior consent. Any broader use, including in platform marketing or promotional materials, requires explicit permission from the nonprofit.
Nonprofits may request removal or exclusion from a platform at any time, and that request must be honored without penalty. A simple mechanism for organizations to opt out of platform discovery is needed so that nonprofits who do not want to be represented can easily be removed. A universal opt-out registry is being developed as a free utility by the Digital Public Goods Network. We hope platforms will use this listing to suppress and/or remove those organizations from their sites. Where a nonprofit has established a presence on a platform, it should also have the ability to manage or decline third-party fundraisers initiated on its behalf. Notifying nonprofits of third-party fundraising activity is not always practicable when a nonprofit has not claimed its presence on a platform; platforms and nonprofits should develop reasonable approaches to this challenge as their capabilities allow.
Platforms agree not to proactively promote donation links for a named nonprofit in external search unless that nonprofit or one of its supporters has actively created a campaign or page for that organization.
Consideration 3 — Responsible Data Use
Donor privacy: Donors have the right to determine how their personal information is shared. Platforms must offer donors a clear and meaningful choice about whether their contact information and giving details may be shared with the nonprofit, including the option to give anonymously.
Nonprofit data access and portability: Nonprofits own their relationships with donors who have not chosen to remain anonymous and should be able to take them when they leave a platform. Upon reasonable request, nonprofits must receive complete, exportable records of all donor information that donors have consented to share in a standard portable format, along with transaction-level data sufficient for accounting and tax purposes. This should be available within a reasonable and clearly stated timeframe, and donor preferences regarding information sharing must travel with that data. Platforms may not prevent nonprofits from contacting donors who have consented to being contacted. Platforms will not sell or rent nonprofit data without the consent of the nonprofit.
Field research and the public interest: Responsible data sharing for public benefit purposes is consistent with the spirit of these considerations. Platforms are encouraged to participate in aggregated, anonymized research initiatives — such as the Fundraising Effectiveness Project — that help the field and the public better understand the state of charitable giving in the United States.
Consideration 4 — Responsible Fund Management
Platforms must comply with all applicable laws governing the collection, holding, and disbursement of charitable funds. Charitable funds should be maintained separately from a platform’s general operating accounts. Platforms must maintain transparent accounting of all funds received and disbursed on behalf of each nonprofit, with regular reporting that gives nonprofits a clear view of funds received, fees deducted, and amounts disbursed. Nonprofits should have a direct escalation path to a human representative when fund disbursement issues arise. During declared emergencies or disasters, platforms should prioritize the expedited disbursement of charitable funds.
Consideration 5 — Resolution and Accountability
Nonprofits deserve fair treatment, clear communication, and a genuine opportunity to be heard when problems arise. Platforms should maintain accessible support channels, provide clear explanations when campaigns are flagged or suspended, and offer nonprofits a meaningful appeals process. Platforms should provide adequate notice of material changes to policies, fees, or operations.
