Federal tax exemption is granted by the IRS, but charities are regulated by the states too. State attorneys general and secretaries of state oversee charitable assets and fundraising, and many of them use the Form 990 as the starting point for their own annual reports.
Why states care
States protect donors and charitable assets within their borders. A state may require a charity to register before it solicits contributions from state residents, and to renew each year with financial information. Many states also oversee organizations that hold charitable assets in the state, such as land, endowments or trusts. Registration is a state matter, separate from your federal filing requirement: being excused from the 990 doesn't automatically excuse you from a state, and the reverse is also true.
How states commonly handle registration
| Approach | What it looks like in practice |
|---|---|
| No general registration | A minority of states don't require charities to register before soliciting. Some of them still regulate particular activities, such as paid fundraisers or charitable trusts, so check before assuming you're clear. |
| Registration plus an annual report with the 990 attached | The most common pattern. California and Illinois, for example, require a copy of the federal return with their own annual form. |
| The 990 accepted in place of a state financial statement | Florida lets a charity submit its Form 990 or 990-EZ instead of the state's financial statement. |
| Audit or review above a threshold | Many states require financial statements reviewed or audited by an independent certified public accountant (CPA) once revenue or contributions pass a set amount. |
| Exemptions | Most states exempt some organizations, commonly religious organizations, and many exempt small, volunteer-run charities. New Jersey, for instance, exempts charities with less than $10,000 in gross contributions whose work and fundraising are all done by volunteers. |
The National Association of State Charity Officials (NASCO) maintains a directory of state charity regulators, which is the best starting point for a state you haven't dealt with before.
Thresholds in seven large states
These are the review and audit triggers published by each state's regulator or in its statutes, as of October 2026. States measure different things (total revenue, gross support and revenue, or contributions only), and none of them is the same as federal gross receipts.
| State (regulator) | Annual filing | Review required | Audit required |
|---|---|---|---|
| California (Attorney General, Registry of Charities and Fundraisers) | Form RRF-1 with the 990, 990-EZ or 990-PF, without Schedule B (990-N filers use Form CT-TR-1); due 4 months and 15 days after year end, IRS extensions honored | No separate review tier | Total revenue of $2 million or more |
| New York (Attorney General, Charities Bureau) | Form CHAR500; 180-day extensions granted | Total revenue and support of $250,000 to $1 million | More than $1 million |
| Illinois (Attorney General) | Form AG990-IL with the 990 (without Schedule B); due within 6 months after year end; 60-day extension on written request; $15 fee for most | Contributions over $300,000 up to $500,000, if fundraising is done only by staff and volunteers | Contributions over $500,000, or over $25,000 raised through a paid professional fundraiser |
| Florida (Department of Agriculture and Consumer Services) | Annual registration renewal with a financial statement, or the 990 or 990-EZ in its place | Annual contributions of $500,000 to under $1 million (review or audit) | Contributions of $1 million or more |
| Pennsylvania (Department of State, Bureau of Corporations and Charitable Organizations) | Registration once gross national contributions exceed $25,000 | Contributions of $250,000 to under $750,000 (review or audit); compiled statements accepted from $100,000 | Contributions of $750,000 or more |
| New Jersey (Division of Consumer Affairs, Charities Registration) | Renewal due 6 months after year end; short form under $25,000 of gross contributions, long form above | Not stated by the Division | Long-form filers with total gross revenue over $500,000 |
| Massachusetts (Attorney General, Non-Profit Organizations/Public Charities Division) | Annual filing with the Division | Gross support and revenue over $500,000 up to $1 million | Over $1 million |
Illinois's current thresholds took effect January 1, 2024. Florida also requires that a 990 submitted by a charity with $500,000 or more of contributions be prepared by a CPA or another professional return preparer.
A calendar-year youth arts charity based in California solicits donors in New York and Illinois. For 2025 it had total revenue of $1.4 million, of which $420,000 counts as "contributions" under Illinois law (which includes gifts plus amounts the public paid for events and merchandise). Its staff and volunteers do all the fundraising.
- California: RRF-1 plus its 990, minus Schedule B, due May 15, 2026 (4 months and 15 days after December 31) unless it extended with the IRS. The renewal fee for revenue between $1,000,001 and $5 million is $200. At $1.4 million it is under the $2 million audit line.
- New York: $1.4 million is more than $1 million, so the CHAR500 needs a CPA audit report.
- Illinois: $420,000 of contributions is over $300,000 but not over $500,000, so it needs at least reviewed financial statements, with its AG990-IL due June 30, 2026.
One set of books, one audit, three different filings.
How the 990 fits in
According to the IRS instructions, some states and local governments accept a copy of Form 990 or 990-EZ in place of all or part of their own financial report, mainly for 501(c)(3) organizations under state charitable solicitation laws. States may also require:
- additional information or attachments beyond the federal return,
- financial statements on the accrual basis, or reporting that follows the AICPA audit guide for not-for-profits,
- audited or reviewed financial statements above a state threshold,
- their own registration form and fee.
Even a 990 the IRS accepted as complete may not satisfy a state if information is missing; the state can ask for more or for an amended return. A Form 990 prepared to meet state rules can generally be filed with the IRS as well, as long as the state's rules don't conflict with the IRS instructions.
Handle Schedule B carefully
Schedule B lists major contributors. IRS guidance warns organizations not to send Schedule B to a state unless the state requires it, because the state may make it public. California and Illinois both tell filers to leave it out entirely; California asks you not to send even a blank or redacted copy. When a state does require it, follow that state's instructions. See Schedule B and public disclosure.
Amended returns
If you amend a Form 990, state law may require you to send a copy of the amended return to the states where you file. A state may even require an amended 990 to fix a state problem when the IRS accepted the original.
Building a state calendar, step by step
- List every state where you are incorporated, have an office or hold assets, and every state where you actively solicit.
- Check each state's rules on the regulator's website: registration, exemptions, annual report, fee and due date.
- Note which states follow the IRS extension. California does; Illinois and New York have their own extension procedures.
- Match your financial statements to the highest audit or review level any of your states requires.
- Put state dates next to your federal due date, so one year-end close covers everything.
Frequently asked questions
We only solicit online. Do we register everywhere?
Online fundraising raises real questions about which states expect registration, and states don't all agree. Start with the states where you are based, hold assets or actively target donors, and get advice on the rest.
Does a state extension follow the IRS extension?
Sometimes. California's Registry, for example, honors IRS extensions. Illinois grants a 60-day extension only on a written request filed before the due date, and New York has its own extension procedure.
Do we need an audit?
Possibly. Several large states require reviewed or audited financial statements once revenue or contributions pass a state-set threshold, from $250,000 for a review in New York or Pennsylvania to $2 million of revenue for an audit in California. If you file in several states, the strictest one sets the level.
What happens if we miss a state deadline?
States set their own consequences, from late fees (Illinois charges $100) to delinquent or suspended registration. California warns that failing to renew can also affect the organization's state tax exemption. If you are behind on federal returns as well, see catching up on late returns.
Sources
- IRS: 2025 Instructions for Form 990, section G and Appendix I. irs.gov
- California Attorney General, Registry of Charities and Fundraisers: annual renewals. oag.ca.gov
- New York State Senate: Executive Law section 172-b. nysenate.gov
- Illinois Attorney General: Form AG990-IL filing instructions (Rev. 01/24). illinoisattorneygeneral.gov
- The Florida Senate: 2025 Florida Statutes, section 496.407. flsenate.gov
- Pennsylvania Department of State: Charitable organizations. pa.gov
- New Jersey Division of Consumer Affairs: Charities registration information. njconsumeraffairs.gov
- Massachusetts Attorney General: Audits and reviews for charitable organizations. mass.gov
IRS figures change; inflation-adjusted amounts are updated each year. We review this page when the IRS publishes new instructions.
990IRS.com is a private company, not the IRS. This page is general information, not legal or tax advice for your organization. Example organizations and figures are hypothetical.
