Mr. Cuomo’s donor-appointees span the state’s vast network of boards and authorities. They have served as trustees of both the city and state university systems, on the panel overseeing economic development and on the board of the Metropolitan Transportation Authority, which runs New York City’s subways and buses. Most positions are unpaid, but they hold great power and prestige: Board members can approve multibillion-dollar contracts and multimillion-dollar grants, oversee the distribution of tax breaks, and have broad influence over everything from the state’s highways to local arts projects.

In response to questions about the donations from appointees, Cuomo administration officials said they believed that the order only applied to appointees who could be fired at any time by the governor, not those serving set terms. Under that interpretation, donations by board members of many of the state’s most powerful authorities would be allowed.

“The purpose of the order is to prohibit employees and board members who serve at the pleasure of the governor from making political contributions,” said Alphonso B. David, Mr. Cuomo’s counsel. “It does not apply to every single person who serves in government, to individuals who volunteer for government, or to individuals who were appointed by the Senate and cannot be removed by the executive. A different reading simply divorces the purpose of the order from its language.”

The Cuomo interpretation differs from what some public authorities say in their own internal ethics rules, from the interpretation of independent government watchdogs and from what Mr. Spitzer himself said he intended when he crafted the order.

“The executive order was intended, and did, in fact, apply to all gubernatorial appointees, regardless of the need for Senate confirmation, or any term applicable to their service,” Mr. Spitzer said in an interview.

The order does not differentiate between types of authority appointees. It simply says that “no member of a public authority appointed by the governor” can donate or solicit donations.