What Does Your Charity Website Tell the CRA, and Why Does It Matter?

In Canada, charities must comply with regulations set by the Canada Revenue Agency (CRA) to maintain their registered status. However, many charities overlook the fact that their websites are also subject to scrutiny by the CRA. A charity’s online presence, including its website content, social media posts, and donation links, can provide important insights to the CRA about its operations, financial management, and mission alignment. This article will guide you through what the CRA looks for on charity websites and how to ensure that your online presence aligns with compliance requirements.

What Triggers a CRA Website Review?

The CRA doesn't review every charity website constantly, but certain situations prompt closer scrutiny of your online presence. Understanding these triggers helps you stay proactive about compliance.

Common Review Triggers

Charity Registration Applications: When you apply to become a registered charity, CRA reviewers examine your proposed website (or existing site) to verify that your stated activities align with your application.

Annual T3010 Filing Discrepancies: If your T3010 return shows $500,000 in donations but your website has no donation functionality, outdated content, or mentions programs not listed in your filing, the CRA may investigate further.

Public Complaints: Donor complaints about misleading fundraising appeals or concerns about how funds are used often trigger a website review as part of the CRA's investigation.

Routine Compliance Audits: The CRA conducts random audits of registered charities. Your website is typically one of the first places auditors look to assess ongoing compliance.

Media Coverage or Public Attention: Charities receiving significant media attention—positive or negative—may see increased CRA scrutiny of their digital presence to ensure public statements align with their registered activities.

Direction and Control Issues: If your charity works with international partners or other organizations, the CRA reviews your website to ensure you maintain proper direction and control over charitable resources.

Understanding these triggers helps you maintain a compliant website before issues arise rather than scrambling to fix problems during an audit.

Why Does the CRA Look at Charity Websites?

‍The CRA checks a charity's website to ensure compliance and mission fulfillment. Here’s what the CRA mainly looks for:

1. Consistency with Registered Purpose

The CRA reviews websites to ensure that a charity’s content aligns with its registered purpose. Any actions that deviate from its purpose or mention unapproved fundraising initiatives may raise compliance concerns.

2. Transparency and Accountability

A well-maintained website demonstrates transparency. The CRA evaluates clear information on how funds are spent, who benefits from programs, and the impact of the charity. Insufficient transparency may indicate poor governance or the potential misuse of funds.

3. Fundraising Information

If your website includes donation links or calls for fundraising, the CRA expects these to be clearly linked to your charity’s mission and purpose. Misleading or overly aggressive fundraising language can result in the CRA scrutinizing how your funds are raised and used.

4. Financial Disclosures

Financial transparency is essential for compliance with the CRA. Charities should think about publishing an annual report or a financial summary on their website. This level of openness can help reassure both the CRA and the public that the charity is responsibly managing its resources.

5. Social Media and Digital Presence

The CRA's website review extends beyond your main website to include your entire digital footprint. This means your charity's social media accounts are also subject to scrutiny.

What the CRA Monitors:

Social Media Platforms: The CRA reviews content on Facebook, Instagram, LinkedIn, Twitter/X, and other platforms where your charity maintains a presence. Posts, fundraising campaigns, stories, and interactions should all align with your registered charitable purpose.

Consistency Across Platforms: If your website states your charity provides educational programs for youth, but your Instagram account shows you selling unrelated products or promoting commercial ventures, this inconsistency will raise red flags.

Fundraising Appeals: Social media fundraising campaigns must be transparent about how funds will be used and must relate directly to your charitable activities. Misleading claims like "100% of funds go to families in need" when administrative costs are deducted could prompt CRA inquiry.

Video and Audio Content: YouTube channels, TikTok accounts, and podcast descriptions are also reviewed. A charity educational podcast that suddenly pivots to selling investment advice or promoting political candidates could indicate activities beyond your charitable mandate.

Third-Party Platforms: The CRA may review your charity's profile on platforms like CanadaHelps, GoFundMe, or other fundraising sites to ensure descriptions and campaigns align with your registered purpose.

Practical Example: A registered charity focused on environmental conservation posted social media content promoting a board member's private consulting business. The CRA flagged this as potential private benefit, leading to an audit and compliance agreement requiring the charity to separate its official communications from board members' personal business activities.

Best Practice: Treat every social media post as an extension of your charitable mission. Ensure staff and volunteers understand what can and cannot be shared on official charity accounts.

Key Elements Your Charity Website Should Include

Here’s a list of essential components your charity website should feature to meet CRA expectations:

1. Mission Statement and Programs

‍Clearly Define Your Purpose: Include a clear mission statement that describes your charity’s registered purpose.

Overview of Programs: Provide details about your programs, highlighting their alignment with the mission and the specific groups they serve.

2. Donor Details

‍Donation Details: Be clear about how donations will be used. Statements such as "100% of donations go directly to programs" can build donor trust and demonstrate accountability.

Receipts and Transparency: Outline your charity’s approach to tax receipts. Let donors know if they will receive a tax-deductible receipt, and clearly explain the process.

3. Financial Reports

Annual Reports: These reports provide a summary of finances, program outcomes, and organizational goals. Ensure they are up-to-date and reflect your charity’s recent activities.

Public Disclosure: Consider including financial summaries, impact statistics, and outcome reports. This information helps both the CRA and donors see the impact of donations and how funds are allocated.

4. Contact Information and Accessibility

Accessible Contact Options: Include contact information, ideally with a phone number, email, and physical address if applicable. Make it easy for stakeholders to reach you for questions or verification.

Language and Accessibility Features: Canada is a bilingual country, and accessibility is a CRA priority. Provide English and French versions of key information and ensure your website meets accessibility standards.

5. Ethical Fundraising and Donor Privacy Policies

Clear Fundraising Language: Avoid misleading or pressuring language in fundraising calls. Ensure that any fundraising campaigns align with your charity’s mission and adhere to CRA guidelines.

Privacy Policy: Outline how you handle donor information to protect privacy. Include details on data storage, security practices, and the handling of sensitive information.

Common CRA Red Flags on Charity Websites

While a comprehensive and transparent website is a great asset, certain pitfalls can lead to unwanted CRA scrutiny. Here are a few red flags that might alert the CRA to issues:

1. Activities That Don't Align with the Registered Purpose

For instance, if a charity registered to combat hunger is advertising paid training courses that don’t directly support food security, the CRA might view this as a deviation from the registered purpose.

2. Overly Commercial Language

Charities should avoid commercial or profit-driven language. Statements like "limited-time donation matching" can seem too sales-oriented and may raise questions about fundraising tactics.

3. Missing or Outdated Financial Information

Not providing updated annual reports, financial summaries, or impact assessments could imply a lack of transparency or mismanagement of funds.

4. Fundraising Appeals with Excessive Emphasis on Financial Need

Although it’s natural to highlight the importance of donations, extreme language suggesting financial distress may cause the CRA to investigate the charity’s financial stability.

5. Inadequate Accessibility Compliance

The CRA increasingly expects charities to demonstrate inclusive practices, including digital accessibility. Websites that fail to meet accessibility standards may indicate poor governance or disregard for serving all Canadians.

Accessibility Red Flags:

No AODA Compliance (Ontario Charities): Ontario registered charities must comply with the Accessibility for Ontarians with Disabilities Act. Non-compliance can trigger both CRA and provincial regulatory concerns.

WCAG 2.0 Level AA Non-Compliance: Canadian government guidelines recommend Web Content Accessibility Guidelines (WCAG) 2.0 Level AA as the minimum standard. Failing to meet these standards suggests inadequate attention to inclusion.

Missing Alternative Text: Images without alt text prevent screen readers from describing visual content to visually impaired users. The CRA views this as a failure to serve all potential beneficiaries and donors.

Poor Colour Contrast: Text that doesn't meet minimum contrast ratios (4.5:1 for normal text, 3:1 for large text) creates barriers for users with visual impairments.

Keyboard Navigation Issues: Websites that can't be fully navigated using only a keyboard exclude users with mobility limitations.

Inaccessible PDFs: Financial reports and annual documents published as PDFs must be screen-reader accessible. Non-accessible PDFs prevent visually impaired stakeholders from reviewing your charity's information.

No Accessibility Statement: While not legally required, an accessibility statement demonstrates your charity's commitment to inclusion and helps users understand available accommodations.

Why It Matters: A charity claiming to serve vulnerable populations while maintaining an inaccessible website contradicts its stated mission and raises questions about genuine commitment to inclusive service delivery.

6. Security and Data Protection Issues

The CRA expects charities to protect donor information and maintain secure digital systems. Security vulnerabilities suggest poor governance and increase risk of fraud or data breaches.

Security Red Flags:

No HTTPS/SSL Certificate: Websites without secure connections (indicated by the padlock icon in browsers) expose donor data to interception. Any site accepting donations or collecting personal information must use HTTPS.

Outdated Privacy Policy: Privacy policies last updated several years ago suggest the charity hasn't reviewed its data handling practices in light of evolving privacy regulations and expectations.

PIPEDA Non-Compliance: The Personal Information Protection and Electronic Documents Act governs how Canadian organizations handle personal information. Privacy policies must outline collection purposes, storage practices, disclosure policies, and individual rights.

Unclear Cookie Policies: Modern websites use cookies and tracking technologies. Failing to disclose what information is collected, how it's used, and providing opt-out options violates privacy best practices.

Third-Party Data Sharing: If your website uses analytics tools, social media plugins, or marketing platforms, your privacy policy must disclose what information these third parties collect and how it's used.

No Data Breach Protocol: Charities should outline procedures for handling data breaches, including notification timelines and remediation steps.

Insecure Payment Processing: Donation pages must use PCI DSS compliant payment processors. Processing credit cards through non-compliant systems exposes your charity to liability and suggests inadequate financial controls.

Contact Form Vulnerabilities: Unsecured contact forms can be exploited for spam, phishing, or data harvesting. Forms collecting personal information must be properly secured.

Why It Matters: A charity that fails to protect donor information risks losing public trust, facing privacy complaints, and demonstrating to the CRA that it lacks adequate internal controls. Security issues discovered during a CRA audit can lead to deeper investigation of other governance concerns.

Real-World CRA Website Compliance Issues

Understanding how the CRA has addressed website compliance problems helps charities avoid similar pitfalls. Here are anonymized examples based on actual compliance cases:

Case Example 1: Unregistered Activities Advertised Online

The Situation: A registered charity with the purpose of "advancing education through literacy programs for children" prominently advertised on its website that it offered paid workplace wellness coaching and corporate team-building seminars. While these activities generated revenue, they weren't educational programs for children and didn't fall within the charity's registered purpose.

CRA Response: During a routine audit triggered by a public complaint, the CRA reviewed the charity's website and identified the corporate services as unrelated business activities. The charity received a compliance letter requiring immediate removal of the commercial content and a detailed explanation of how revenues from these activities were used.

Resolution: The charity had to:

• Remove all corporate service advertising from its website within 30 days
• Demonstrate that corporate program revenues were less than 10% of total revenues
• Show that profits from unrelated activities were used exclusively for charitable programs
• Revise its T3010 to properly report unrelated business income
• Implement board oversight policies to prevent future deviations from purpose

Lesson: Every program, service, or activity mentioned on your website must connect directly to your registered charitable purpose. If you offer services outside your mandate, even to generate revenue for charity, you must carefully structure these activities and seek legal advice to ensure compliance.

Case Example 2: International Activities Without Proper Documentation

The Situation: A Canadian registered charity focused on poverty alleviation described extensive international projects on its website, including building schools in three African countries and operating medical clinics in South America. The website prominently featured these international activities and solicited donations specifically for overseas projects.

CRA Response: The CRA's compliance division reviewed the charity's website after receiving questions from a potential major donor. The website suggested the charity directly operated foreign programs, but the charity's T3010 and documentation showed insufficient evidence of direction and control over these activities.

Resolution: Upon investigation, the charity couldn't demonstrate:

• Written agreements with foreign partners
• Adequate oversight of how funds were used internationally
• Regular reporting from foreign partners
• Site visits or third-party monitoring
• Clear decision-making authority over program activities

The CRA issued a direction and control compliance agreement requiring the charity to:

• Revise website content to accurately describe its role (funding vs. operating)
• Implement proper direction and control mechanisms for all international activities
• Cease direct appeals for international projects until documentation was in order
• Provide quarterly reports to the CRA for two years

Lesson: Your website must accurately represent your charity's actual role in programs and activities. If you fund international work but don't directly operate programs, say so. Claims of "operating" programs you don't control violate direction and control requirements.

Case Example 3: Misleading Donation Impact Claims

The Situation: A charity supporting homeless individuals claimed on its donation page: "Your $100 donation houses a homeless person for a month" and "$50 provides a week of meals." These specific dollar-to-impact claims appeared throughout the website and social media.

CRA Response: During an audit, the CRA examined the charity's actual program costs and found:

• Average monthly housing cost per client was $1,850 (including support services)
• Weekly meal costs averaged $180 per person
• Administrative and fundraising costs consumed 35% of donations

The simplified donation impact statements were materially misleading because they didn't reflect actual program costs or the portion of donations used for overhead.

Resolution: The CRA required the charity to:

• Remove or substantially revise all donation impact claims
• Add disclaimers explaining that stated amounts represent partial program costs
• Clearly disclose administrative and fundraising expense percentages
• Provide donors with realistic expectations about how funds are allocated
• Review all marketing materials with legal counsel before publication

The charity faced a three-month suspension of its authority to issue tax receipts while corrections were implemented, significantly impacting fundraising.

Lesson: Donation impact claims must be accurate, complete, and not misleading. Simplifying for marketing purposes can cross the line into misrepresentation. Always include context about actual program costs and expense allocation.

Key Takeaways from These Cases

These examples demonstrate that:

1. The CRA takes website content seriously as evidence of how your charity actually operates
2. Public complaints often trigger website reviews that lead to broader audits
3. Corrections must be swift and complete once the CRA identifies issues
4. Documentation must support website claims about programs, impact, and international activities
5. Marketing language doesn't excuse compliance violations – accuracy always trumps persuasive messaging

Your website isn't just a marketing tool; it's a compliance document the CRA uses to assess your charity's adherence to regulatory requirements.

How to Regularly Audit Your Website for Compliance

1. Update Content Regularly

Plan an annual review of your website content to ensure everything aligns with your mission and meets CRA requirements.

2. Engage Key Stakeholders

Have the board of directors or a compliance committee review major updates to your website to ensure everything aligns with CRA standards.

3. Regularly Verify Financial Information

Make sure that your financial disclosures are updated and accurate, ideally after each fiscal year-end.

4. Align with CRA’s Guidance on Fundraising

Consult the CRA’s Fundraising by Registered Charities document. Use this as a checklist to ensure your website follows all regulations.

‍A charity's website serves as a window into its operations, financial responsibility, and commitment to its mission. For Canadian charities, maintaining a compliant website isn’t just about meeting CRA regulations; it’s also about building donor trust and community credibility. By keeping your website transparent, up-to-date, and mission-focused, you’re not only keeping the CRA satisfied but also strengthening your organization’s reputation with the public. Make regular updates, include clear disclosures, and focus on accessibility to ensure that your charity’s online presence reflects the best of what you have to offer.

‍Conclusion

Your charity's website is more than a digital brochure—it's a compliance tool that speaks directly to the CRA about your governance, transparency, and mission alignment. Ensuring your online presence meets CRA standards protects your charitable status and builds donor trust, but navigating these requirements can be complex.

B.I.G. Charity Law Group specializes in helping Canadian charities create compliant, effective websites. Whether you need a website review, policy development, or ongoing compliance support, we provide practical legal solutions tailored to your needs.

Schedule a FREE consultation today at CharityLawGroup.ca or call 416-488-5888. Email us at dov.goldberg@charitylawgroup.ca. Let us help you turn your website into a powerful tool for compliance and impact.

Frequently Asked Questions

We've answered some common questions about charity websites and why they matter for Canadian registered charities.

Why do charities have websites?

Charities have websites to share information about their mission, programs, and impact with the public. A website helps charities connect with donors, volunteers, and the communities they serve. It also shows transparency by displaying how donations are used and what the charity accomplishes. For Canadian registered charities, a website demonstrates accountability to both the CRA and supporters.

Are charity websites credible?

Most charity websites are credible, but it's important to verify the information. A credible charity website includes clear contact information, financial reports, and details about their registered charitable status. You can check if a charity is legitimate by searching the CRA's online list of registered charities. Look for transparency in how they describe their programs and use of funds.

What is a charity website?

A charity website is an online platform where a registered charity shares information about its purpose, activities, and impact. It typically includes the charity's mission statement, program details, donation options, financial reports, and contact information. The website serves as a public window into how the charity operates and uses donations to fulfill its charitable purpose.

How can you tell if a charity is legitimate?

You can verify a charity's legitimacy by checking the CRA's list of registered charities online using the charity's name or registration number. A legitimate charity will have clear contact information, a defined mission that matches its registered purpose, and transparent financial reporting. Be cautious of charities that use high-pressure fundraising tactics or refuse to provide details about how donations are used.

Should a charity have a website?

Yes, every Canadian registered charity should have a website. A website helps meet CRA expectations for transparency and accountability. It allows donors to easily learn about your work, make informed giving decisions, and verify your charitable status. While not legally required, a website is now considered essential for building trust, attracting donors, and demonstrating compliance with CRA standards.

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