The principles, in practice
The four principles · The six checks · Evidence standard
On 24 June 2026 the National Council of Nonprofits published four principles for online fundraising platforms, endorsed by 52 state and regional associations of nonprofits. We think they are right. This page sets each one beside what the register finds, so the principles can be checked, not just agreed with.
Nonprofit Consent
“Nonprofits must have the power and agency to decide for themselves how and when to engage with online fundraising platforms before they solicit or collect donations.”
What the principles ask of platforms
- “Obtain the written consent from an authorized representative of the nonprofit before soliciting or collecting donations on their behalf.”
- “Only use logos, branding, images, or messaging affirmatively provided by the nonprofit.”
Quoted from NCN’s principles, “Nonprofit Consent” section.
What the register finds
- 13 of 15 listed platforms generated pages themselves, check 2.
- 12 of 15 put pages live without the nonprofit’s consent, check 3.
- 12 of 15 take gifts on those pages, check 4.
Transparency
“Donors must have the power and information they need to decide whether to make a donation through an online fundraising platform.”
What the principles ask of platforms
- “Make it clear to donors whether tips are provided to the online fundraising platform or the nonprofit, separate out the options for donors to cover processing fees from a suggested tip rather than combining both into one option, and never make suggested tips the default.”
- “Disclose whether the online fundraising platform is a nonprofit or for-profit entity, and whether the platform uses a donor-advised fund (DAF) rather than sending the donation directly to the charity.”
Quoted from NCN’s principles, “Transparency” section.
What the register finds
- 6 listed platforms preselect a tip: Pledge, GreatNonprofits, JustGiving, Bright Funds, Spotfund, and B Charitable. See the tip / fee column.
- 14 of 15 route the gift through a fund the nonprofit does not control, check 5.
NCN says the principles are not written to guide donor-advised funds themselves. The register’s Routers are those funds; the principles still ask the platforms that use them to say so.
Partnership
“Online fundraising platforms must recognize nonprofits as valued, equal partners.”
What the principles ask of platforms
- “Not require nonprofits to register or agree to terms and conditions in order to remove their organization from the platform. Registration should be free of charge.”
- “Not use paid search engine optimization unless the nonprofit consents.”
Quoted from NCN’s principles, “Partnership” section.
What the register finds
- 11 of 15 publish nonprofit pages to search engines, check 6. The check measures indexing, not paid search, so it is the nearest test, not the same one.
- The register has verified a removal route for 17 platforms so far: RoundUp.org, Donate.gg, GiveFreely, Network for Good, Pledge, GoFundMe, GreatNonprofits, PayPal Giving Fund, JustGiving, Meta / Facebook, Every.org, DonateStock, Bright Funds, Givelify, Spotfund, B Charitable, and Uncommon Giving. Each is on the platform’s page.
Accountability
“Online fundraising platforms must be accountable to nonprofits, donors, the public, and the appropriate regulators.”
What the principles ask of platforms
- “Comply with all applicable state laws.”
- “Publicly report on at least an annual basis to donors, recipients, and government regulators on the number of donations received by nonprofits, the total number of donations redirected or refunded, net dollars given to each nonprofit, all fees collected by the platform, and other relevant information.”
Quoted from NCN’s principles, “Accountability” section.
What the register finds
- Every legal action, takedown and reform is dated and sourced in the event log.
The six checks
Whole Whale defined the Shadow Donation Page in October 2025. Each clause of that definition is one check, and so is the search harm named in the sentence that follows it. A platform is listed when the evidence shows its pages meet the definition.
- 1
Is the page hosted by someone other than the nonprofit?
The page lives on the platform’s domain, not the nonprofit’s.
From the definition: “a third-party, off-domain giving page”
- 2
Did the platform create the page itself?
The platform built the page, typically from the IRS exempt-organization file, before anyone at the nonprofit touched it.
From the definition: “auto-generated”
- 3
Did the nonprofit never opt in?
The page went live without the nonprofit authorizing it. A notice saying the nonprofit has not claimed the page does not change this: disclosure is a mitigation, not an exemption.
From the definition: “without the nonprofit’s consent”
- 4
Does the page take donations in the nonprofit’s name?
A visitor can complete a donation on the page, addressed to the nonprofit.
From the definition: “accepts gifts on the org’s behalf”
- 5
Does the money pass through a fund the nonprofit does not control?
Gifts are received by an intermediary fund, sponsor, or donor-advised fund that can hold the money, and reassign it if the nonprofit never claims it.
From the definition: “routing payouts through an intermediary”
- 6
Are the pages exposed to search engines?
The platform publishes its nonprofit pages to search engines, through a public sitemap and no noindex, so a donor searching for the nonprofit can land on the platform instead of the nonprofit’s own donate page.
From the definition: “can outrank or confuse results of the official donate page in search”
Four states
- Yes, dated evidence
A dated, hashed evidence bundle shows the platform does this.
- No
The platform does not do this.
- Unclear
We looked, and the evidence does not settle it yet.
- Not checked
We have not looked yet. This says nothing about the platform either way.
- Yes, research only
Whole Whale’s published research says the platform does this, but no dated evidence bundle carries it yet. The outline turns solid once a capture backs it, or the mark is withdrawn.
Evidence standard
Every platform we examine gets its own investigation, filed in a dated evidence directory. Once written, an evidence directory is never overwritten. A re-check creates a new one.
- Anonymous public captures. We fetch pages as any visitor would. We do not create accounts or make donations.
- Hashed bundles. Each capture keeps its response headers, a UTC capture log, archive.org snapshots, and a SHA-256 checksum file.
- Screenshots for what a page displays. A claim about what a visitor sees comes from a browser screenshot, never from raw HTML, which can show placeholder values no visitor ever sees.
Absence is not a finding
We reason from evidence, never from silence. A platform missing from this register has not been examined. A check marked not checked means only that we have not looked.
Disclosure is a mitigation, not an exemption
Some platforms tell donors that the nonprofit has not claimed the page. That helps, but the page still exists without the nonprofit’s consent, and the platform stays listed.
Platforms can leave the register
A platform that changes what it does is re-examined and moved to the reformed tier, and the change is logged with its date. Charity Navigator moved in September 2026 after it made donations opt-in, and GoFundMe in October 2026 after its remaining charity pages all showed a claim by the organization.
Who examines
Whole Whale examines every platform and publishes the results. We name companies and cite public IRS records. We do not name individual officers, and we do not publish associations we have not verified.
Replies and corrections
A platform named here, or anyone with evidence we have something wrong, can write to report@shadowdonation.org. We publish replies and log every correction with its date.
Before you build a giving page for a nonprofit
Our checklist, drawn from the principles and from the register’s six checks. If a step feels like friction, that friction is the nonprofit’s consent.
- 1Get written consent first.
From someone authorized to give it, before the page solicits or takes a gift. An IRS listing is not consent.
- 2Keep unclaimed pages out of search.
A donor looking for the charity should find the charity’s own donate page.
- 3Show every fee, and never preselect a tip.
Say who gets the tip, and show the net amount the nonprofit receives.
- 4Say where the money goes.
If a donor-advised fund holds the gift, say so, say how long it takes to arrive, and say whether it can be sent elsewhere.
- 5Let a nonprofit leave without signing up.
Removal should not require registering, agreeing to terms, or sharing bank details.
- 6Report what you collected.
Donations received, redirected or refunded, net dollars to each nonprofit, and every fee.
Why this is here
The principles say what ethical platforms should do. The register records what platforms actually do, with dated evidence, so the gap between the two is visible to nonprofits, donors, regulators and anyone thinking of building the next one.
Regulators are asking platforms the same questions. Read the March 2026 multistate letter to GoFundMe, explained, with its six demands beside GoFundMe’s reply.
NCN reports that one platform in the register, Every.org, has endorsed the principles. Since October 2026 Every.org shows a Donate button only on profiles the nonprofit has created with Every.org’s approval, and the register now lists it as reformed; its row shows which checks it still meets.
Donations are starting to move through AI agents, and an agent asked to give to a charity can land on a shadow page as easily as a donor can. We hope the Verified Giving Protocol becomes a standard that nonprofits adopt to take control of their agent donation flows. It lets a nonprofit publish, from its own domain, the giving destinations it authorizes, so an agent can check where a gift should go before it sends one. Whole Whale wrote the protocol; it is open and free to use.
To report a page that breaks these principles, email report@shadowdonation.org. To add your organization’s name to the principles, use NCN’s endorsement form.