The change of heart was prompted by one of Intelligent Giving's funders, which suggested it should become a charity to enable it to claim back Gift Aid.
A commission spokeswoman said: "We recently received an application for registration from Intelligent Giving, which we are considering. We have asked for additional information."
Intelligent Giving is independently financed and run. To date, its funding has come from benefactor Peter Heywood and grant giver Beyond the Barn.