Nonprofit donor mobilization in California: AG registration and IRS rules

What to take away

California AG charity registration: triggers and forms

In California, the Attorney General's Registry of Charitable Trusts oversees charitable solicitation. Any nonprofit that receives or solicits funds in the state must register within 30 days of receiving assets. The initial registration uses Form CT-1. After that, annual reporting is required.

The annual report is Form RRF-1, filed within four months and fifteen days after the fiscal year ends. The fee is based on total revenue, ranging from $25 to $1,000. Failure to file leads to a $25 late fee per month, up to $100. The AG can also revoke tax exemption.

For donor mobilization, your first outreach cannot happen until the registration is active. A California address on a donation page does not substitute for the registration. The AG publishes a searchable registry, so donors and platforms can verify status.

For a comparison of another state's rules, see our guide on nonprofit donor mobilization in New York, which covers Article 7-A and the Charities Bureau filings.

FTB and Secretary of State filing triggers

The California Secretary of State must receive your articles of incorporation before you conduct any business, including fundraising. This step is separate from the AG registration. The filing fee for articles of incorporation is $100.

The Franchise Tax Board requires an Application for Recognition of Exemption under Section 23701d, using Form 3500. This is for state income tax exemption. Once approved, you file Form 199 annually. The FTB also charges a minimum franchise tax of $800 per year for corporations, though nonprofits may be exempt.

The trigger for FTB filing is any solicitation of funds from California residents. If you send a single email to a California donor, you may create a filing requirement. The FTB cross-checks with the AG registry.

IRS substantiation limits for donor mobilization

The IRS requires a written acknowledgment for any single donation of $250 or more. The acknowledgment must include the amount, date, and whether any goods or services were provided. Without it, the donor cannot claim a deduction. For payroll giving, the pledge card can serve as substantiation if it includes the same details.

For quid pro quo contributions over $75, you must provide a disclosure statement estimating the value of goods or services. This applies to auction items, gala tickets, and merchandise. The penalty for failure is $10 per contribution, up to $5,000 per event.

The IRS substantiation and disclosure requirements page explains these limits in full. Donor mobilization campaigns often overlook these rules. A thank-you email that only says "thanks" does not meet the standard. You need to include the required language.

This is a compliance step that also builds donor trust. For email reactivation, follow the FTC CAN-SPAM compliance guide to avoid spam violations. Protect donor data with the FTC data security guidance.

Example: a California health nonprofit

A small health nonprofit in Sacramento planned a year-end email campaign. Before sending, the board checked the AG registry status. They found the RRF-1 was two years late. They filed the missing reports and paid $75 in late fees. Then they applied for FTB exemption.

The campaign raised $40,000. Every donor who gave $250 or more received a written acknowledgment with the required language. The nonprofit used a simple template from their CRM. They also added a checkbox for donors to opt out of future emails.

California's AG registry is public, so donors can verify your status in seconds.

Common questions

Do I need to register with the California AG if I only solicit online?

Yes. The AG's registration requirement applies to any solicitation, including email, social media, and website donations. The trigger is receiving or soliciting funds in California.

What is the IRS limit for donor substantiation?

Written acknowledgment is required for single donations of $250 or more. For quid pro quo contributions over $75, you must provide a disclosure statement. The IRS substantiation page details these rules.

How does California differ from New York and Texas?

California uses the AG Registry of Charitable Trusts and Form RRF-1. New York uses Article 7-A and the Charities Bureau, while Texas uses the Secretary of State and the AG's consumer protection division. For Texas, see our guide on nonprofit donor mobilization in Texas, and for strategy, read our nonprofit marketing strategy guide, and visit nonprofit donor mobilization home for more.