.png)
.png)
In an earlier article we compared how Denmark, Finland, Sweden, Norway and Iceland treat the tax deductibility of charitable gifts. This is the companion piece, and it asks the question that comes before tax ever enters the picture: are you even allowed to ask the public for a donation, and who decides?
As a peer-to-peer fundraising platform working across the Nordics, BetterNow deals with these rules every day, so we gathered our research into one place and wanted to share it.
On tax deductions, all five countries run a statutory scheme of some kind. On fundraising permits the picture is the opposite: the five split cleanly into two camps. And the split does not fall where most people would guess. Denmark, Finland and Iceland all require permission or a notification before you may fundraise publicly. Norway and Sweden require nothing from the state at all, relying instead on voluntary self-regulation. Iceland, which many assume has little in place, turns out to have one of the oldest fundraising laws of the group, while Norway scrapped its own attempt at a register a decade ago.
In what follows we set out the rules country by country, compare the costs side by side, tell the short story of the Norwegian experiment, and then look at the evidence on whether the lighter-touch approach actually does any harm.
The first camp regulates fundraising by law. In Denmark a public collection must be approved or notified to a state board, in Finland it requires a permit from the police, and in Iceland it requires a permit or notification from a district commissioner. In all three, fundraising without the relevant permission is unlawful.
The second camp leaves fundraising unregulated by the state. Norway and Sweden have no fundraising permit and no law setting out how a collection must be run. Trust is handled instead by independent, voluntary bodies that approve organisations and publish lists donors can check. We return later to the question of which model serves donors and the sector better, and we bring data to it.
Denmark regulates fundraising through the Collections Act (indsamlingsloven) and the Collections Board (Indsamlingsnævnet), which sits under the Civil Affairs Agency. The Board approves collections and supervises that funds are used for the stated purpose. There are two routes, set out in section 3 and section 4 of the Act, and the difference between them matters.
Section 3 is the ordinary, per-collection route. Anyone with a Danish company registration number (a CVR number) can apply, the permit covers one stated purpose for up to one year, and the collection must be notified to the Board at least two weeks before it starts. Afterwards, accounts must be submitted. The application fee is 1,300 DKK (around 175 EUR in 2025).
Section 4 is the route for what are in effect registered, continuous collectors. It is open only to organisations already approved under the tax law as eligible to receive deductible gifts - the same approval we covered in the tax-deduction article. A section 4 organisation can run collections continuously, for several purposes at once, without notifying each individual collection, for up to three years at a time.
The fee is 11,700 DKK (around 1,570 EUR). In practice this is the fast lane reserved for the large, established organisations, while everyone else uses section 3.
On top of the permit, there is an accounting rule that bites hardest on small fundraisers. Under the executive order on collections (Bekendtgørelse 160 of 26 February 2020), any collection that raises more than 50,000 DKK (around 6,700 EUR) must have its accounts audited by a state-authorised or registered auditor. Below that threshold no auditor is required.
Denmark does have an exemption for private collections - appeals made within a closed circle of members or people with a personal connection to the cause. In reality the exemption is narrow. The moment an appeal is directed at the general public it becomes a collection that needs a permit, and a public Facebook post is, by definition, public. For most real-world fundraising the exemption does little useful work.
House-to-house and street collections face additional restrictions and are generally reserved for larger organisations granted specific permission. Collectors must carry clear identification, and the Board emphasises that house collections must leave at least two-thirds of the funds for the stated purpose.
Sources and more information: Indsamlingsnævnet (Civilstyrelsen) and indsamlingsloven.
Finland regulates fundraising through the Money Collection Act, substantially reformed and in force since 1 March 2020, and administered by the National Police Board. A money collection permit is open only to non-profit associations and foundations pursuing a public-benefit purpose.
The 2020 reform made permits simpler in one respect and more demanding in another. Permits granted from March 2020 are valid until further notice rather than for a fixed term, so an organisation no longer reapplies every few years.
In return, every permit holder must submit an annual report on the previous year's collecting and an annual plan for the year ahead, and a processing fee applies to each. The permit itself costs around 530 EUR in 2026, up from 400 EUR in 2025.
Finland also offers a light route for small actors. A small-scale money collection requires only a notification to the local police, not a full permit. It is capped at 10,000 EUR, may run for a maximum of three months, may be held at most twice a year, and can be organised by a group of three residents aged 15 or over. The notification fee is around 120 EUR in 2026 (it was 90 EUR in 2025 and 68 EUR in 2024), and no audit is required.
Sources and more information: Finnish Police - money collection permits.
Iceland's fundraising rules are the oldest of the group. Public fundraising is governed by Act no. 5/1977 on public fundraising and administered by the District Commissioner of South Iceland (Sýslumaðurinn á Suðurlandi). Street, shop and house collections require a permit, while other public fundraisers require a notification. In either case a responsible person must be named, the funds must be held in a dedicated account, and an audited collection account must be filed within six months.
Two features stand out. The first is that the permit and notification appear to be free of charge - public fundraising is not listed in the district commissioners' fee schedule, so we infer there is no fee, though we could not confirm this positively.
The second is the audit obligation. Iceland requires an auditor-reviewed account for every collection, with no de minimis threshold of the kind Denmark applies. The smallest Icelandic collection therefore carries the same audit duty as the largest.
The law also exempts several specific activities, including charity auctions, benefit concerts, collections of used goods, and fundraisers run through the media. This public-fundraising regime is separate from the public-benefit register (almannaheillaskrá) we discussed in the tax-deduction article.
Sources and more information: Act no. 5/1977 on public fundraising and the District Commissioner of South Iceland (Sýslumaðurinn á Suðurlandi).
Norway has no fundraising permit and no law setting out how a collection must be conducted. Trust is handled privately. Innsamlingskontrollen, a non-profit foundation established in 1991, approves organisations against accounting rules and ethical guidelines and maintains a public list of approved organisations that donors can consult. Separately, the general register of voluntary organisations (Frivillighetsregisteret) offers basic registration, free of charge since March 2023, though it is general registration rather than fundraising approval. The Ministry of Culture and Equality is preparing a new register law expected to go to consultation in 2026.
This was a deliberate choice, and Norway reached it the hard way. We cover that detour in the section "The Norwegian experiment" below.
Sources and more information: Innsamlingskontrollen and the Norwegian register of voluntary organisations.
Sweden has no fundraising law and no permit to collect. One footnote applies: a physical collection in a public place can require a police permit under the public order act, but that regulates the use of public space rather than fundraising itself, and it does not touch online or peer-to-peer giving.
Trust rests on two voluntary pillars. Svensk Insamlingskontroll issues the 90-konto, a seven-digit control account number available only to non-profit associations, foundations and religious congregations, which are audited annually so that donors have reliable information on how gifts are used. Giva Sverige, the membership body, operates a quality code and lets compliant members carry the "Tryggt givande" (secure giving) mark.
Sources and more information: Svensk Insamlingskontroll and Giva Sverige - Tryggt givande.
The table below summarises the position. Euro figures are approximate conversions for mid-2026, and exchange rates move, so treat them as indicative.
Norway is the one country of the five that tried the middle ground and walked away from it, which makes its story worth telling briefly.
In 2007 Norway passed a law on the registration of collections. It came into force on 1 July 2009 and created a statutory register, run in practice by Innsamlingskontrollen, that organisations could opt into as a state-backed seal of trust. The idea was a voluntary register with a legal footing.
It did not work as hoped. Uptake was modest and the arrangement was seen as bureaucratic and as weighing on the fundraising organisations it was meant to support. After a review by PwC in 2013, the government put repeal out to consultation in 2014 and the law was repealed in 2015.
The official rationale was deregulation: rather than maintain a register that had proven not to work, the state would lean on the general register of voluntary organisations for transparency, and leave assurance to the independent, private oversight that already existed.
The result is the Norwegian model as it stands today, with no statutory fundraising regulation and trust handled through Innsamlingskontrollen. A decade later, as we will see, Norwegian giving is in robust health.
Each of the three statutory countries offers a "lighter" route, but each is light in a different dimension, and none is light on all of them.
Finland's small-scale collection is light on both fee and audit, but capped on size. It is an easy on-ramp for a one-off effort up to 10,000 EUR, after which an organisation moves to the full permit and its annual reporting.
Denmark's section 3 permit is cheap to obtain and open to anyone with a company number, and its audit requirement is tiered so that small collections escape it, but the paperwork applies to every collection, and the cheap continuous route under section 4 is reserved for the large, tax-approved organisations.
Iceland charges no fee at all, but its audit obligation applies to every collection regardless of size, which makes it the most demanding of the three for the smallest fundraisers.
The Danish audit threshold is the clearest illustration of how a fixed cost can fall unevenly. A local sports club that raises 70,000 DKK clears the 50,000 DKK line and must engage a state-authorised or registered auditor. The fee for that audit consumes a share of the proceeds that a large organisation raising millions would never notice, but that is significant for a club raising a modest sum for, say, new kit.
The cost is the same in kroner whether the collection is small or large, so its weight as a proportion of funds raised rises sharply as the collection shrinks.
That raises an obvious question. Does this friction actually change how much gets raised, or is it a paperwork irritation that washes out in practice? Here there is evidence, and it points in one direction.
Peer-to-peer fundraising is a poor test of the regulatory question, because most of those donations flow to established charities that already hold permits. Donation-based crowdfunding is a much cleaner test. It is the grassroots, ad-hoc giving - the campaign for a sports club's new jerseys, the local project, the disaster appeal - run by people and groups who hold no existing permission. It is precisely the activity that a per-collection permit and audit requirement weigh on most, and it lets us compare two countries that are similar in almost every respect except how they regulate.
The contrast between Denmark and Norway is large. In 2022, donation-based crowdfunding in Denmark raised around 11 million DKK, about 2 per cent of the Danish crowdfunding market. In Norway the same year, donation crowdfunding raised 278 million NOK, about 12 per cent of the Norwegian market. Norway and Denmark have near-identical populations, so in per-capita terms the Norwegian market is more than twenty times the size of the Danish one.
Both national reports exclude Facebook, so the gap is not an artefact of one country counting a channel the other leaves out.
The most striking part is who draws the link. Denmark's own export and investment fund, EIFO, set out the likely reasons in its 2022 crowdfunding report:
Donation crowdfunding makes up just 2 per cent of the Danish market. That is somewhat lower than in Norway, where donation crowdfunding makes up around 12 per cent. In Denmark, several administrative conditions may matter. Donation crowdfunding is legally classified as a collection, which means donations must be reported to the Collections Board to ensure the funds are used for the stated purpose. In addition, collections over 50,000 DKK must have their accounts audited by a state-authorised or registered auditor.
In other words, a Danish public body points to the permit regime and the audit threshold as administrative conditions that help explain why donation crowdfunding is less widespread in Denmark than in Norway.
Honesty requires the other half of EIFO's explanation. The report gives two reasons, and it gives the regulatory one second. Its first point is that Norwegian banks own and actively promote several of the large Norwegian platforms, which gives those platforms reach and distribution that the Danish market lacks. The gap, then, has at least two causes, and platform ownership is a real part of the story.
What we can say with confidence is that even the Danish government's own analysis treats the permit and audit rules as a contributing cause, which is a strong statement to be able to make. It would overreach to claim regulation is the sole driver.
One caveat on the data: 2022 is the most recent year for which we found donation-specific figures that are comparable across both countries. The matched national reports both cover 2022, so that is the year we use.
If the absence of a permit harmed the sector, the deregulated countries ought to lag on the broadest measure of all, the share of the population that gives. They do not. The Nordic Donor Report 2026 puts the share of active donors in 2026 at 70 per cent in Norway and 69 per cent in Sweden, ahead of Denmark at 66 per cent and well ahead of Finland at 48 per cent. The two countries with no fundraising permit sit at the top of the table. Giving has also risen across all four markets between 2024 and 2026, and Norway has climbed to the highest figure of the group a full decade after it repealed its register.
These are correlations from a survey that was not designed to test regulation, so they cannot prove cause and effect, and Finland's lower figure has its own drivers, including the narrow design of its tax scheme. The fair reading is a modest one: there is no evidence that the absence of a fundraising-permit regime depresses giving, and the broad pattern, if anything, runs the other way.
Sources and more information: EIFO, Dansk crowdfunding - tendenser fra 2022; Crowdfunding in Norway 2022 (Norwegian Crowdfunding Association / University of Agder); Nordic Donor Report 2026.
Everything above is intended as a fair comparison. This section is where we set out what BetterNow takes from it, and readers are free to weigh the same facts differently.
The central difference between the two camps is when the cost of compliance falls. In Norway and Sweden the cost is opt-in. A small group can start fundraising from the first day at no cost, and earn an independent trust seal later if and when it grows large enough to want one.
In Denmark, Finland and Iceland the cost is, for most public fundraising, mandatory before the first appeal can go out, and the crowdfunding comparison suggests that this friction has a real price measured in grassroots giving that never happens.
We think trust can be built through transparency and independent seals rather than through state gatekeeping. The Swedish 90-konto and Norwegian Innsamlingskontrollen show that a recognised, audited mark can give donors a clear signal of reliability, and the donor data shows that the markets relying on those marks are neither giving less nor, as far as any evidence we found shows, more exposed to fraud.
It is worth adding that for online and digital fundraisers, KYC and anti-money-laundering checks are already obligatory and always carried out at the payment and platform level. Those fundraisers could therefore be exempted from a permit without raising the money-laundering or terror-financing concerns that are often cited in defence of the Danish regime.
There is a reasonable argument on the other side, and it deserves stating plainly. A statutory permit gives donors a single, state-backed assurance and one official place to verify that a collection is legitimate, whereas a voluntary seal puts more onus on the donor to look for the mark and understand what it means.
Our answer is that the seal model achieves much the same assurance without imposing a fixed cost on the small, spontaneous fundraisers who can least carry it, and that the permit model's main visible effect is a smaller grassroots sector rather than measurably stronger trust.
The five Nordic countries divide neatly into two camps on fundraising regulation. Denmark, Finland and Iceland require a permit or notification by law, with audit and reporting obligations attached. Norway and Sweden require nothing from the state and lean on voluntary, independent oversight instead. Iceland regulates more than its reputation suggests, and Norway tried the regulated middle ground and deliberately left it.
The lighter-touch countries are not the laggards in giving. On the one clean head-to-head we have, donation-based crowdfunding, the deregulated Norwegian market is many times the size of the Danish one, and the gap is one that a Danish public body itself partly attributes to the permit and audit rules. As giving continues to move towards social and peer-led channels, regimes built around a permit for each individual collection look increasingly out of step with how people actually give.
We hope this comparison has been useful. As with the tax-deduction systems we looked at previously, the Nordic countries share a great deal and still arrive at strikingly different answers, and the contrasts between them are a good place to think about what fundraising regulation is really for.
.png)
