"I've got to compete. I'm just saying it's a smarter way to do it than just to waste taxpayers' money - or my money, in this case, on advertising."
The charities involved are Women's Refuge, Conservation Volunteers, KidsCan and Lifeline.
A spokesman for TOP said all the charities had agreed to take part in the event.
Some of the $41,500 allocation could be used for the internet advertising on the campaign if the Electoral Commission approved it.
The broadcasting allocation traditionally only covered advertising on television or radio, but the rules were recently changed to allow it to be used for internet advertising as well.
The broadcasting allocation is the only avenue for parties to buy advertising time on radio and television, and can only be used for ads broadcast after Writ Day (August 23).
The funding can be used to buy the air time, as well as for production costs. Parties cannot use their own money to buy air time - but can top up the production costs with their own funds.
A TOP spokesman said the Electoral Commission had advised the party that the $1 million for charity would not count as election spending, so would not have to be included in the party's spending cap. That is a cap of up to $3 million on advertising in the three months before the election. The cap depends how many electorates a party stands candidates in.
Electoral law expert Graeme Edgeler said TOP's plan did not appear to breach electoral rules but it was possible the charitable donations could also have to be declared as a donation to The Opportunities Party from Morgan.