Legal Insights — EN

Does Sharing an IBAN Online Constitute Fundraising?

Online donation appeals require review of wording, audience and campaign model. Use of an IBAN alone does not resolve permission and notification requirements.
A phone, unmarked account strip, donation funnel and permission file

Donations, Fundraising and Financial Operations

Donations, Fundraising and Financial Operations

Prepared by: Constantinople

Sharing an account number online does not produce the same legal result in every situation. The content of the post, public appeal, organisation around a particular purpose or campaign and method used are assessed together. Ordinary acceptance of donations must be distinguished from fundraising. Since the Fundraising Law also regulates activities through electronic systems, being online alone cannot be said to remove permission requirements. The account belonging to the organisation does not by itself fulfil every obligation either.

The review requires the proposed wording, images, web addresses, target audience, beneficiaries, duration, account holder and intended use of funds. If several persons or organisations participate, responsibility must be clarified. Another organisation's permission does not automatically extend to a person making a different appeal in their own name. Requesting money into a personal account, even ostensibly for an organisation, requires separate examination of representation and records. Preserve dates and screenshots of content already published.

The full course of the campaign should be assessed, and permission applications and explanatory wording planned together within that scope. If the administration requests removal, information or a defence, service and response deadlines are addressed separately. Deleting content does not automatically erase earlier transactions; lawful preservation of records remains important.

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