Nonprofit Compliance Checklist

Keeping track of your nonprofit’s annual compliance requirements can feel overwhelming. That’s why CalNonprofits has compiled this handy comprehensive checklist to help nonprofit 501(c)(3) organizations stay up-to-date with annual filing requirements. Find them here, all in one place, with links to the resources you need if you have questions.

This checklist was developed by CalNonprofits in consultation with the California Attorney General’s Office and the CA Franchise Tax Board. Although we make every effort to identify errors and fix broken links, please help us keep up-to-date by contacting info@calnonprofits.org should you find errors.

You can download a PDF of the Checklist here. You can also watch a March 2023 webinar: That Nonprofit Deadline is More Important Than You Thought with speakers from the Attorney General’s office and the CA Franchise Tax Board. For online renewals, see the Online Renewal System Checklist from the Attorney General’s office.

California nonprofits have many forms to file each year, some with various departments of the State of California, others with the IRS.
Key state offices include:

Dealing with delinquencies

To find out if you have missed any state filings, go to this registry search tool and look up your nonprofit by name or FEIN to determine your status with the Attorney General’s office. Statuses include: “Current,” “Delinquent,” “Not Registered,” or “Suspended.”

If your organization is listed as suspended or delinquent, review the Frequently Asked Questions (FAQs) on curing delinquency or use this link to email the Attorney General’s office and ask for assistance. Our members have found the AG’s staff to be cordial and helpful. Please be aware that failure to remedy delinquencies may lead to penalties, withholding of grants, and even revocation of your tax-exempt status.

State Forms for all CA 501(c)(3) nonprofits

Checkbox graphicAnnual Registration Renewal Fee Report (RRF-1 Form)

All charities, regardless of receipts or assets (except those specifically exempted such as religious congregations, hospitals, and schools) must file the Annual Registration Renewal Fee Report (RRF-1 Form) no later than four months and 15 days after the close of the organization’s calendar or fiscal year (e.g., if the fiscal year ends on December 31, this form is due on May 15). The purpose of Form RRF-1 is to help the Attorney General’s Office detect fiscal mismanagement and unlawful use of charitable assets. This form requires a fee of between $25 and $1,200 based on your organization’s total revenue that year.

Note: The RRR-1 requires that you attach a copy of your 990, 990EZ, 990PF, 1120, or submit a treasurer’s report (Form CT-TR-1). Nonprofits with gross receipts of less than $50,000 in a fiscal year must file the Annual Treasurer’s Report (CT-TR-1 Form and Instructions) along with Form RRF-1 when they renew their registration with the Attorney General’s office.


Checkbox graphicExempt Organization Annual Information Return (FTB Form 199) (Instructions)

Nonprofits with gross receipts of more than $50,000 in the year must file this annual return from the State of California. This form must be filed on or before the 15th day of the fifth month after the close of your organization’s fiscal year (for example, if your fiscal year ends December 31, the form is due no later than May 15). Private foundations are required to file Form 199 regardless of the gross receipts amount.

If your nonprofit had $50,000 or less in gross receipts, instead of Form 199 you should file the Annual Electronic Filing Requirement for Small Exempt Organizations FTB 199N (the “California e-Postcard”) – this no-cost form has the same due dates as FTB Form 199. (And see note above related to CT-TR-1 that must be filed with the CT-TR-1.)

Extension of time to file: Unless your organization is under suspension on the due date of the 199 or the 199N, you will be given an automatic extension of six months. No need to apply for the extension.

Checkbox graphicStatement of Information (Form SI-100)

All nonprofits must file the Statement of Information (Form SI-100) every two years – with the Secretary of State. The form may be filed electronically and has a fee of $20. This form is first due within six months of filing the initial Articles of Incorporation and thereafter is due every two years during the calendar month that the Articles of Incorporation were filed and can be filed up to five months in advance of that date. (For example, if your organization was formed in March of 2016 by filing your Articles of Incorporation, then you must file SI-100 by March of 2016, 2018, 2020, 2022, and so forth.)

Forms for some nonprofits

Checkbox graphicNonprofits with employees or independent contractors

There are very few differences between nonprofits and for-profits when it comes to employment laws and regulations. See the “Forms and Due Dates” section of the California Employer’s Guide.

Checkbox graphicNonprofits seeking a welfare exemption from property taxes

File the annual California Board of Equalization Form 267-A with your County Assessor. (Note this is a sample form; the actual form is available through your county assessor.) A list of county assessors’ contact information is here.

Checkbox graphicOrganizations that have filed IRS Form 5768

If your organization has filed Form 5768 to report limited political or legislative activities during the year, you must file the Political or Legislative Activities by Section 23701d Organizations Form (Form 3509). This form is where such activities are reported, and it must be attached to Form 199.

Checkbox graphicNonprofits with unrelated business income (UBI)

Be sure to file Exempt Organization Business Income Tax Return (FTB Form 109) (Instructions) – This form must be filed for years when you had gross income of more than $1,000 from a trade or business unrelated to your exempt purpose. The form must be filed on or before the 15th day of the fifth month after the close of the fiscal year (for example, if the year ends June 30, the form is due no later than November 15).

Checkbox graphicNonprofits that sold items in California, or purchased items but did not pay sales tax (online, for example):

For the most part, nonprofits must follow the same rules as others when it comes to sales tax and use tax. There are some detailed and specific exemptions for nonprofits, with special rules pertaining, for example, to museums purchasing art, friends of libraries selling books, veterans organizations selling American flags, thrift stores benefiting people with AIDS or HIV, sales of food at youth sports events with free admission, and so forth. See this Tax Guide for Nonprofit Organizations from the California Department of Taxes and Fees (CDTFA) for the complete set of rules and a list of required forms.

Nonprofits that had a raffle or that are planning a raffle:

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Nonprofit Raffles Checklist – A checklist of forms and deadlines for nonprofits conducting a raffle

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Nonprofit Raffle Registration Form (CT-NRP-1) – Form to be submitted by nonprofits conducting a raffle from September 1 through August 31. This form must be submitted and approved before conducting a raffle. Plan for it to take up to 30 days.

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Nonprofit Raffle Report (CT-NRP-2) – Use this form to report all raffles conducted during the reporting year. This form is due on or before October 1. If you registered to hold a raffle but did not do so, you must still file a Nonprofit Raffle Report stating that you did not have a raffle).

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Nonprofit bingo, charity poker, or “Monte Carlo” night? These games use devices (unlike raffles) and so are regulated by the Bureau of Gambling Control in the State Department of Justice (see the laws here). Pre-approval is required (estimate 30 days for the approval process). Not all California counties permit these games, and some may have additional rules. The Charitable Gambling Registration form can be filed online and requires a $100 fee.

Federal Forms (IRS)

ALL nonprofits must annually file one of the following three forms:

Checkbox graphicReturn of Organization Exempt from Income Tax (Form 990) (Instructions)

This is the federal government’s annual information return for tax-exempt organizations. The form must be filed on or before the 15th day of the fifth month after the close of the organization’s taxable year (e.g., if the year ends December 31, the form is due no later than May 15).

Checkbox graphicShort form Return of Organization Exempt from Income Tax (Form 990-EZ) (Instructions)

Tax-exempt organizations with gross receipts less than $200,000 and total assets at the end of the tax year less than $500,000 can opt to file this form rather than Form 990. The form must be filed on or before the 15th day of the fifth month after the close of the organization’s taxable year (e.g., if the year ends December 31, the form is due no later than May 15).

Checkbox graphicAnnual Electronic Filing Requirement for Small Exempt Organizations (Form 990-N)

This is the federal government’s annual information return for tax-exempt organizations that normally have gross receipts of $50,000 or less. The form must be filed on or before the 15th day of the fifth month after the close of the organization’s taxable year (e.g., if the year ends December 31, the form is due no later than May 15); extended due dates are not applicable.

If you are a private foundation, you must file Form 990PF. (Instructions)

If you have unrelated business income, file Exempt Organization Business Income Tax Return (Form 990-T) (Instructions) – Form 990-T is used by a tax-exempt organization to report unrelated business income if it has gross income of $1,000 or more from a regularly conducted unrelated trade or business. The form must be filed on or before the 15th day of the fifth month after the close of the organization’s taxable year (e.g., if the year ends December 31, the form is due no later than May 15).

Other Useful Resources

• Attorney General’s Guide for Charities – Provides practical information and answers to questions frequently asked about charities and summarizes some of the laws governing nonprofits.

• Fundraising firms – Whether you’re working with a “commercial fundraiser” or “fundraising counsel,” each needs to register with the Registry of Charities and Fundraisers before beginning work with you. “Commercial fundraisers” file Form CT-1CF and “fundraising counsel” use Form CT-3CF.

• General Guide for Dissolving a Nonprofit Corporation – Outlines the steps that should be taken to dissolve (close down) a California nonprofit organization.

• Amendment of a California Nonprofit Corporation’s Articles of Incorporation – This form is used to amend provisions of the Articles of Incorporation.

• Registration of an Unincorporated Nonprofit Association – Form used to register an unincorporated nonprofit association.

Please note that the above list does not include forms related to employees, healthcare provision, facility management, or other forms not specifically for nonprofits.

This resource is provided for informational purposes only and does not constitute legal advice. CalNonprofits encourages nonprofits to seek assistance from qualified professionals for guidance on what federal and state and filing obligations.