Google Play deems AnkiDroid's 501(c)(6) donation host not tax-exempt; removal looms 11 September

Google Play rejects AnkiDroid over its donation link

Google has been rejecting updates to AnkiDroid since 28 August over the app's Open Collective donation link, and unless the dispute is resolved the app will be pulled from Google Play on 11 September in every country except India and Russia. That account comes from a public GitHub issue posted by the project's volunteer maintainers, which reached the front page of Hacker News.

AnkiDroid is a free, open-source flashcard app for Android with more than 10 million installs, used primarily for medical education and language learning. According to the maintainers, nothing is sold inside the app, all development is volunteer-run, and the project's Open Collective — whose ledger is public — is its only source of funding. The project is independent of Anki, AnkiWeb, AnkiMobile and AnkiHub.

Where the policy collision happens

Google Play's payments policy bars apps from steering users to any payment method other than Play's billing system, with a carve-out in Section 3 for cases including "tax exempt donations". An automated notice dated 20 July flagged a payment-policy violation and listed the remedies: submit documentation such as an IRS determination proving the donation recipient is tax-exempt, remove the donation feature, collect donations through Play's in-app purchases, or enrol in Google's US alternative payment or external content link programs.

AnkiDroid's donations flow to Open Source Collective, a US non-profit that serves as the project's fiscal host and holds an IRS determination letter establishing tax exemption under 501(c)(6). The team submitted that letter to Google. In a 6 August email, Google said donations may only be collected for "a validated tax-exempt organization (for example, a validated 501(c)(3) charitable organization in the United States or the local equivalent)". A day later, after receiving the 501(c)(6) determination, Google wrote that AnkiDroid "allows users to contribute donations to an organization that is not tax-exempt". Support has since repeated that finding without explaining why a 501(c)(6) determination does not satisfy the policy.

The crux is that 501(c)(6) is itself a form of federal tax exemption, even though donations to such organisations are not tax-deductible for the donor the way gifts to 501(c)(3) charities are. As the AnkiDroid team points out, Google's own communications say "tax-exempt", not "tax-deductible", which leaves open whether reviewers are conflating the two concepts or applying an unwritten rule that only charities qualify.

What AnkiDroid is doing

Facing removal from the distribution channel most of its users rely on, the team says it will strip donation links from the Play Store build in the 2.24.x series immediately, under protest; otherwise it could no longer reach the majority of its install base. Its open support case with Google is #9-2777000041594. What the team says it actually needs is clarification on whether an IRS 501(c)(6) determination satisfies the policy's donation exception. It is asking readers to share the post, especially with anyone inside Google who can help, and explicitly asking people not to contact Google support on its behalf.

Why it matters

If Google's reading holds, any Android app funded through a 501(c)(6) fiscal host — a common structure in open-source funding — faces the same fork: drop the donation link, route gifts through Play billing, or accept removal from the store. For volunteer projects with no other revenue, an exception designed to accommodate donations becomes a funding cutoff.

It also illustrates the asymmetry of app-store enforcement. A volunteer team with more than 10 million users has no recourse beyond the appeal process, and Google has, per the issue, offered no reasoning after being handed exactly the documentation its own notice requested. With a hard removal deadline of 11 September, an ambiguous policy question has become a distribution crisis for a study tool that medical students and language learners depend on.