Before You Spend Your Ad Grant: The Charitable Registration You Need First
Your Google Ad Grant just came through, and you're ready to build your first donation campaign. One of the first settings Google asks for is where your ads should show, whether that's a few cities, a handful of states, or the whole country.
Before you choose, check where your charity is registered to fundraise. About 40 states require a charity to register before it asks their residents for donations, and a donation ad shown to people in one of those states asks them for money.
Get the order right, and you can spend your full grant each month without a state ordering you to pull ads. This article covers two ways to align your ad targeting with your registrations, what states ask for, and what can happen if your ads run first.
At a Glance
- About 40 states require a charity to register before it asks its residents for donations.
- A donation ad asks for money, so it can count as a solicitation in each state where it runs.
- Google's legal requirements policy says you must comply with the local laws of any area your ads target.
- You can register only in the states you plan to target, or register broadly and run your donation ads nationwide.
- Each state sets its own filing requirements, process, and fees for charitable solicitation registration.
- Running donation ads before you register can hurt your credibility with donors, lead to state fines, and trigger cease-and-desist orders.
What Your Google Ad Grant Covers and What Google Expects From You
Qualifying nonprofits get up to $10,000 a month in free search ads, according to the Google Ad Grants FAQ. You can spread that budget across several campaigns, but anything you don't spend is gone at the end of the month. Our guide to Google Ad Grants for nonprofits covers eligibility and the application process.
Getting in takes 501(c)(3) status and a check by Goodstack, the partner Google uses to verify nonprofits under its nonprofit eligibility rules. Your website has to pass muster, too. The entire site must run on HTTPS, and every donation link must work and lead to a secure giving page, per Google's website policy for grantees.
Grantees also agree to follow the regular Google Ads rules as set forth in the Ad Grants program policies. Under the Google Ads legal requirements policy, you're responsible for complying with the local laws and regulations of any area your ads target. Google doesn't mention charitable registration by name, but if your ads ask for donations, state fundraising laws are among the local laws that apply.
Two Ways to Line Up Your Ad Targeting With Your Registrations
Google asks grantees to be specific about location. Its account management policy says to target the places where people will find your nonprofit's information and services useful. For donation campaigns, the states you can safely target depend on where you're registered, and that leaves you two options.
Option A: Register Selectively and Target Only Those States
With this option, you register in a limited set of states and set each donation campaign's locations to match those states. Google suggests separate campaigns by geography when your services differ locally and nationally, and that setup also keeps donation ads inside your registered states while your program ads run more widely.
Our guide to online fundraising adds one more step for organizations with a smaller fundraising footprint: state on your website that you don't accept donations from states where you aren't registered.
A narrower campaign shows your ads to fewer people, which can make it harder to spend the full grant each month, and the unspent balance doesn't carry over.
Option B: Register Broadly and Advertise Nationwide
With this option, you register in every state that requires it, file for exemptions where you qualify, and then run donation ads across the US. Our online fundraising guide calls this the best option for organizations that plan to fundraise nationwide.
Google's own fundraising example fits this approach. Its account management policy describes a group doing relief work in Nepal whose donors live in the United States and says that the group should run its ads across the US.
Registering broadly takes more filings up front. In return, you can run efficient nationwide campaigns without checking every campaign's location settings against a list of registered states.
When a Donation Ad Counts as a Charitable Solicitation
What makes an ad a solicitation is the request for money. An ad promoting your programs or volunteer openings isn't asking anyone for a gift, while a donation ad is, and state charity laws regulate that request.
Many states define solicitation broadly enough to cover requests made through any medium, and some explicitly include online and electronic requests. Here's how five states describe it:
| State | What the definition covers |
|---|---|
| North Dakota | What the definition covers: Requests for a contribution made by electronic communication, including the internet, or through other advertising or communication media (N.D.C.C. § 50-22-01) |
| West Virginia | What the definition covers: Appeals made by email or messaging, electronic bulletin board, or internet technology, plus written advertisements that seek public support (W. Va. Code § 29-19-2) |
| Connecticut | What the definition covers: Any oral, written, electronic, or online request for money or other things of value for a charitable purpose (Conn. Gen. Stat. § 21a-190a) |
| New York | What the definition covers: Any direct or indirect request for a contribution, express or implied, made through any medium (Executive Law § 171-a) |
| Pennsylvania | What the definition covers: Requests made by radio, television, or other advertising or communication media (10 P.S. § 162.3) |
In North Dakota, West Virginia, Connecticut, and New York, a solicitation counts as having taken place whether or not anyone gives, so your ad can be the request before a single dollar arrives. West Virginia also treats the solicitation as occurring where the request is received, which matters when your ads reach the state from elsewhere.
Mississippi's charity rules address paid online ads directly. An organization that spends money on internet solicitations aimed at Mississippi residents counts as soliciting in the state, according to the Mississippi Secretary of State's charities rules. For other states, see our list of charitable solicitation laws.
What States Require Before You Can Solicit
Each state sets its own filing requirements, process, and fees for charitable solicitation registration. Fees vary and are often based on your gross revenue from the prior year, as our charitable registration guide explains. Keeping up with those differences in every state you target is a large part of the work, and it's the part our team handles for you.
Pennsylvania, for example, wants an annual registration statement, your IRS Form 990, and financial statements. Florida lets you send a copy of your Form 990 (or a 990-EZ with Schedule O) instead of filling out its own financial statement.
Several states also require financial statements reviewed or audited by an independent CPA once you pass a set dollar level. It pays to check what each one measures, since some go by gross revenue and others by contributions:
| State | Measure | When a review or audit applies |
|---|---|---|
| California | Measure: Gross revenue, not counting government grants and contracts | When a review or audit applies: Audited statements from an independent CPA at $2 million or more (Gov. Code § 12586) |
| Florida | Measure: Annual contributions | When a review or audit applies: Optional under $500,000, review or audit from $500,000 up to $1 million, and an audit at $1 million or more (Fla. Stat. § 496.407) |
| Pennsylvania | Measure: Annual contributions | When a review or audit applies: Compilation, review, or audit from $100,000 up to $250,000, review or audit from $250,000 up to $750,000, and an audit at $750,000 or more |
| Massachusetts | Measure: Gross revenue | When a review or audit applies: Review or audit above $500,000, and only an audit above $1 million (Massachusetts Attorney General FAQ) |
Massachusetts requires registration with the Attorney General's Office before you raise money in the state, whether or not your organization is based there. For other states, our overview of charitable audit requirements is a good place to start.
Labyrinth, our nonprofit brand, determines what each state requires based on where you fundraise, then prepares and files your initial registrations, renewals, and Form 990 attachments.
Colorado adds a step before you even get to charity registration. Out-of-state nonprofits count as foreign entities there, so you'll first file a Statement of Foreign Entity Authority in the state's business filing system, according to the Colorado Secretary of State. That filing is a form of foreign qualification, which means registering your organization to operate in a state other than the one where you formed it.
You may have heard of the Unified Registration Statement (URS), a single paper form meant to cover one initial registration with several states. As of June 2025, only seven states accepted it, according to the Multi-State Filer Project: Arkansas, Georgia, Illinois, Kansas, Minnesota, Oregon, and Virginia. It doesn't work for annual renewals either, and the project itself says its use is now limited because most states require online filing.
What Happens If Your Ads Run Before You Register
According to our charitable registration guide, soliciting before you register can lead to:
- State fines, late fees, and penalties
- An order to stop soliciting in that state, which means pulling your ads there
- Unspent Ad Grant budget, since paused ads leave money that doesn't carry over to the next month
- Civil or criminal action against officers and directors
- Lost donations and grants, along with damaged credibility with donors
Examples from three states:
- Florida: Officials can order you to stop specific fundraising, refuse or suspend your registration, and fine you. For a 501(c)(3) that hasn't registered, the fine tops out at $500 per violation under Fla. Stat. § 496.419, charged once per violation rather than daily.
- Pennsylvania: The state can fine you up to $1,000 per violation, plus $100 per day while the violation continues. The Department of State generally issues a cease-and-desist order only after it has notified you of the requirement and you still haven't registered or shown that you're exempt. In fiscal year 2024-25, it issued 12 new orders and had 528 in effect, per its 2025 Annual Charities Report.
- Nevada: If the Secretary of State finds you soliciting without a filed registration, the office imposes a penalty and sends written notice to your registered agent, the person or company you've named to receive official mail in that state. Our registered agent service covers all 50 states, so a notice like that reaches someone who will act on it.
A Pre-Launch Checklist for Ad Grant Campaigns
Start with your ad creative and the angle of your donation ask. From there, the steps depend on which option you chose.
If you register selectively:
- Confirm your registration or exemption in each state you plan to target.
- Set each donation campaign's location settings to those states only.
- Leave out any state where your registration is still awaiting approval.
- Add a note to your donation page listing the states where you accept donations.
- Launch, and expect a smaller audience and a harder time spending the full grant.
If you register broadly:
- Register in every state that requires it, and file for exemptions where you qualify.
- Set your donation campaigns to the US and launch.
For either option:
- File any foreign qualification a state wants first, the way Colorado does.
- Pull together your latest Form 990 and any reviewed or audited statements your revenue level calls for.
- Test your donation page to make sure it works and loads over HTTPS, per Google's website policy.
- Put every renewal date on your calendar so your registrations stay current while the ads run.
Leave yourself time for the registrations before launch day.
Registering Before Your Campaign Launches
Once you're registered in every state your donation ads reach, you can run your campaigns without second-guessing your location settings. Every state you target is covered, and you can use the full monthly grant to reach donors.
Ready to match your registrations to your campaign plan?
Talk to a registration specialist at Labyrinth. Our team will go through your state list with you and take the filings off your plate, so you can focus on your mission.
Charitable solicitation registration - A state filing that lets a charity ask that state's residents for donations.
Foreign qualification - Registering your organization to operate in a state other than the one where it was formed.
Geo-targeting - Choosing the cities, states, metro areas, countries, or regions where your Google ads appear.
Solicitation - A request for a donation, whether it's made in person, in print, or online. Many states count it as a solicitation whether or not anyone gives.
Unified Registration Statement - A single paper form for initial charity registration, accepted by seven states as of June 2025.
Frequently Asked Questions
In many cases, yes. A donation ad solicits money and notes that charitable solicitation laws generally require registration before asking residents to donate. Some states, such as North Dakota and Connecticut, name internet or online requests in their definitions of solicitation, so check the rules in every state your campaign reaches before you launch.
Not every state, but most of them. A nationwide campaign reaches all 50 states, yet only those with charitable solicitation laws require registration, and the IRS puts that number at about 40. Some of those states exempt certain organizations, and if you can't register everywhere before launch, limit your location settings to the states where you're already registered.
According to IRS guidance on registration, about 40 states have charitable solicitation laws, and those states usually require you to register before asking their residents for money. The Multi-State Filer Project's count of 40 includes the District of Columbia. Rules change, so confirm the details with each state's charity regulator before your ads run.
It's a filing with a state charity regulator that lets your nonprofit ask that state's residents for donations. Depending on the state, you may need a registration statement, your IRS Form 990, and financial statements, which may be reviewed or audited by a CPA. Pennsylvania, for example, asks for all three.
Look for a team that tracks each state's requirements, handles both initial registrations and renewals, and keeps a clear record of what was filed and when. It helps if they can also match your registrations to the states your ad campaigns target. Labyrinth, Inc., our nonprofit brand, offers this kind of charitable registration support.
