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GDPR2 min readBy ComplyMo Team

Nonprofit websites and the six state privacy laws that now apply

Which state privacy laws reach nonprofits, what Oregon says about donor lists, and the 2027 accessibility deadline for HHS grantees.

Key takeaways

  • Six states now apply consumer privacy laws to nonprofits; California's CCPA generally doesn't.
  • HHS-funded nonprofits face a WCAG 2.1 AA deadline of May 11, 2027.

The exemption nonprofits counted on is shrinking

Colorado, Oregon, Delaware, New Jersey, Minnesota and Maryland cover nonprofits that meet their thresholds, as low as 35,000 consumers in Delaware and Maryland. All but Maryland require honoring Global Privacy Control.

What Oregon says about donor data

Oregon's nonprofit FAQ (opens in a new tab) says swapping donor lists may be a sale, and newsletter emails can't be reused for solicitations without consent.

Donation pages and trackers

Regulators check whether donation-page pixels stop when a browser sends Global Privacy Control; California, Colorado and Connecticut ran a joint sweep (opens in a new tab) in September 2025.

Accessibility for grantees and everyone else

After a May 2026 extension (opens in a new tab), HHS-funded nonprofits with 15 or more employees must meet WCAG 2.1 AA by May 11, 2027, and smaller ones by May 10, 2028. ADA Title III also covers nonprofit food banks and shelters.

What to do

Check each state where supporters live, honor GPC, and audit donation pages for labels and captions. ComplyMo honors GPC and holds pixels from one line of code, and audits your pages on Growth and up; it doesn't manage donor data or your CRM. See ComplyMo for nonprofits.

General information, not legal advice. Confirm your obligations with counsel.

Frequently asked questions

Does the CCPA apply to nonprofits?

Generally no, but six other states' laws do.

Do we have to honor Global Privacy Control?

In Colorado, Oregon, Delaware and New Jersey, yes, if you meet their thresholds. It's the safer course everywhere.

Is swapping donor lists a sale?

In Oregon it may be, according to the state's own nonprofit FAQ. Check with counsel before exchanging lists.

Sources

  1. Oregon DOJ: Privacy law FAQs for nonprofits (opens in a new tab)
  2. Colorado Attorney General: Colorado Privacy Act (opens in a new tab)
  3. Delaware Code, Title 6, Chapter 12D (opens in a new tab)
  4. Minnesota Statutes 325M.12 (opens in a new tab)
  5. California Attorney General: CCPA (opens in a new tab)
  6. Federal Register: HHS extension of Section 504 web compliance dates (May 11, 2026) (opens in a new tab)
  7. California Attorney General: Joint GPC sweep (Sep 9, 2025) (opens in a new tab)

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