AnkiDroid Pulled Its Donation Link After Google Play Confused Two Tax Codes
Google Play told AnkiDroid its donation host is not tax exempt. Open Source Collective holds an IRS 501(c)(6) determination, and the policy actually turns on a different question entirely.
The WJS Desk
Sep 2, 2026 · updated 1 hour ago · 6 min read
AnkiDroid, the Android client for the Anki spaced-repetition flashcard system, is stripping its donation link out of version 2.24.X. Google Play rejected the app on 28 August and set a removal deadline of 11 September in every region except India and Russia. The maintainers are complying, in their words, "under protest".
The stated reason is a tax classification. Google told the project its donation link points at "an organization that is not tax-exempt". That organization is Open Source Collective, which holds an IRS determination letter as a tax-exempt 501(c)(6). We read the policy, the determination status and Open Source Collective's own documentation, and the interesting part is that Google's conclusion is defensible while the sentence it used to justify it is simply wrong.
Twenty-one days of talking past each other
The timeline in the project's issue tracker runs like this. On 20 July, Google issued the first rejection notice. On 21 July, Open Source Collective supplied its IRS 501(c)(6) determination letter. On 6 August, Google rejected the documentation and repeated that the organization "is not tax-exempt". On 7 August, AnkiDroid asked for clarification on whether a 501(c)(6) determination satisfies the policy. Google restated its position. On 28 August the app was rejected outright, with removal scheduled for 11 September.
What the maintainers asked for was narrow and reasonable: tell us whether 501(c)(6) counts. They never got an answer to that question, which is why three weeks of correspondence produced nothing but a deadline.
What the policy actually says
Google Play's payments policy requires Play billing for in-app purchases, then lists carve-outs where it must not be used. The relevant clause covers cases where "payments include peer-to-peer payments, online auctions, and tax exempt donations". Charitable organisations are not otherwise addressed, and the phrase doing all the work is "tax exempt donations".
Here is where the two sides are answering different questions.
| 501(c)(3) | 501(c)(6) | |
|---|---|---|
| Organisation is tax exempt | Yes | Yes |
| Donations deductible for the donor | Yes | No |
| Open Source Collective holds this | No | Yes |
Open Source Collective is explicit about this in its own docs: it is a 501(c)(6), not a registered 501(c)(3) charity, and donations to hosted member projects are not tax-deductible. Its documentation also explains why, and the reason is upstream of Google entirely. The IRS does not treat producing open source software as a charitable activity in itself, so open source fiscal hosts generally cannot obtain 501(c)(3) status. Projects with a distinct charitable purpose are pointed toward a 501(c)(3) fiscal sponsor instead.
What we found when we checked
Read the exception as written and Google's outcome holds up. The carve-out is for tax exempt donations, and a donation to an OSC-hosted collective is not one, because it is not deductible for the person making it. Under that reading AnkiDroid either routes donations through Play billing or removes the link, and it chose to remove the link.
The sentence Google actually sent is a different claim, and it is false. Open Source Collective is tax exempt. 501(c)(6) is a tax exemption; what it lacks is donor deductibility. Google's notice asserted something about the organisation when its own policy turns on something about the donation, and then repeated that assertion twice when handed a determination letter proving the opposite.
If you maintain an app with a funding link: the exposure is not your project's status, it is your fiscal host's. Any Play-distributed app pointing at an Open Collective page hosted by Open Source Collective sits behind the same clause, and nothing in this case suggests AnkiDroid was singled out for anything other than being noticed.
We have not asked Google for comment and we do not know whether reviewers are now applying this to other OSC-hosted apps, or whether AnkiDroid's rejection was an isolated review. It is also possible Google's team was using "tax-exempt" loosely as shorthand for "deductible", in which case the policy is coherent and only the wording was broken. That would be a better outcome for the policy and a worse one for anybody trying to appeal, because it means three weeks were lost to imprecise language rather than to a substantive disagreement.
The thread that split on whether Google was right
The Hacker News discussion reached 290 points and 47 comments, and unusually for a story about platform power, the technical readers came down partly on Google's side.
"Isn't it pretty obvious that the problem is the donations aren't tax-exempt, despite the organization being tax-exempt? Logically, the payment processor should worry about the taxability of the transaction rather than the tax status of the recipient, right?"
That is dataflow, who identified the exact distinction inside the first few comments and also quoted Google's notice verbatim.
"These donations aren't tax exempt. 501(c)(3) are tax exempt. If users are paying via Google pay these payments must be tax exempt to the user."
free652, arriving at the same place from a different direction. SigmundurM went further and quoted Open Source Collective's documentation back at the thread.
The other camp read it as precedent rather than tax law. amiga386 pointed at Google ejecting WireGuard from the Play Store in 2019 over a donation link, and argued that "this is why software should not be subjected to an app store type distribution system, where a monopolist retains absolute control of what software can run on your devices". We checked that precedent: WireGuard was pulled on 16 October 2019 under the same payments policy, Jason Donenfeld's appeal was rejected, and he removed the donation link to get back in. Seven years apart, identical script, identical ending.
The sharpest line in the thread was aimed at the maintainers, not Google. sunaookami quoted the "under protest" wording and replied: "So you are still complying." That is the uncomfortable part. Protest without leverage is a changelog entry.
zetanor raised the option nobody wants, which is Google's alternative billing programme, noting it comes with a Play service fee. We have not verified the fee schedule and are not quoting a rate here, but the shape of the choice is clear enough: pay a cut on donations, or do not collect them in the app.
Why this is bigger than one flashcard app
The fiscal host model exists because most open source projects are too small to run their own legal entity. Open Source Collective is the default host for a large share of Open Collective projects, which makes it the single point of failure for in-app funding links across the ecosystem. And because the IRS will not treat writing open source as charity, the one status that clearly satisfies Google's exception is the one the model structurally cannot reach.
The practical consequences for maintainers are narrow. Move funding links out of the app and onto the website, which is what WireGuard did and what AnkiDroid is now doing. Use GitHub Sponsors, which westurner raised in the thread as an alternative route. Or find a 501(c)(3) fiscal sponsor, which only works if your project has a charitable purpose the IRS recognises, and most do not.
What we would actually like is duller than any of that. Google's policy hinges on a distinction its own rejection notices get wrong, and a policy nobody can appeal because the reviewer is citing the wrong statute is not really a policy. One clarifying sentence in the payments documentation, saying whether the test is donor deductibility or organisational exemption, would have saved this project three weeks and would save the next one from repeating it.
