Does charity streaming require solicitation registration?

You ask an interesting question to which the answer is likely to differ among the 38 states and the District of Columbia that now have charitable solicitation registration requirements on their books.

The regulators don’t all agree whether registration is required in their state if you merely have a “donate now” button passively sitting on your website.  Twenty-five years ago, state Attorneys General generally agreed with the so-called “Charleston Principles” that they wouldn’t enforce registration requirements merely because you had the button available on your website, but would require registration if you actively sent solicitations into their jurisdictions by means such as mail, email, telephone or advertisements in newspapers or magazines.  That consensus is long gone, and a few states are actively seeking to require registration by all charities that give their residents the opportunity to contribute through the solicitation on the website.  Enforcement varies among the states, but the risk of not registering is increasingly apparent.

Streaming sounds more like pushing the requests out from your state into all the others (like emailing a newsletter) than merely having a button on your site that people might happen to find in surfing the net.  I haven’t heard of regulators challenging charities specifically because they use streaming services, but the risk is always out there.

As to foreign contributions, there are a number of foreign countries that require local charities to register to solicit within their jurisdictions, but not all of their rules pertain directly to U.S. charities.  I am not aware of any efforts by foreign countries to force U.S. charities to register there.  There is an entire industry of providers offering to help charities meet the increasingly difficult requirements to register nationally within the U.S.  There is no corresponding industry offering to help U.S. charities register abroad.