At a Glance

Oregon nonprofits must complete three primary annual filings to maintain good standing: federal IRS Form 990 series (due 15th day of 5th month after fiscal year end), Oregon Department of Justice Form CT-12 or CT-12F (due 4 months and 15 days after fiscal year end), and Oregon Secretary of State Annual Report (due on incorporation anniversary). Missing these deadlines can result in tax-exempt status revocation, administrative dissolution, or significant penalties.

Introduction

Running a successful Oregon nonprofit means more than just doing good work—it means staying on top of crucial paperwork deadlines throughout the year. When you’re busy serving your community, these administrative tasks can easily slip through the cracks. However, the consequences of missed filings can be severe, potentially jeopardizing everything your organization has worked so hard to build.

Fortunately, maintaining compliance doesn’t have to be overwhelming. This comprehensive guide walks you through all the essential Oregon nonprofit annual filing requirements you need to know about. From federal IRS Form 990 submissions to Oregon-specific Department of Justice reports and Secretary of State filings, we’ll break down exactly what you need to file, when it’s due, and how to submit everything correctly.

Let’s dive into keeping your nonprofit in perfect standing so you can focus on your mission, not paperwork headaches.

Federal Filing Requirements: IRS Form 990 Series

In general, exempt organizations are required to file an annual return with the Internal Revenue Service (IRS), although there are exceptions. The Form 990 series serves as the IRS’s primary tool for gathering information about your organization’s finances, governance, and activities. For comprehensive guidance, see the IRS page on annual filing requirements for exempt organizations.

Which version of Form 990 to file

The version of Form 990 your organization must file depends primarily on your annual gross receipts and total assets:

• Form 990-N (e-Postcard): For organizations with gross receipts normally ≤ $50,000. Learn more on the IRS page for the Form 990-N e-Postcard.
• Form 990-EZ: For organizations with gross receipts < $200,000 AND total assets < $500,000.
• Form 990: For organizations with gross receipts ≥ $200,000 OR total assets ≥ $500,000.
• Form 990-PF: Required for all private foundations, regardless of financial status.

Additionally, if your nonprofit generates $1,000 or more in unrelated business income, you must also file Form 990-T for unrelated business income.

Filing deadlines and extensions

Your Form 990 is due by the 15th day of the 5th month after the end of your organization’s fiscal year. For example, if your fiscal year ends December 31, your form is due May 15 of the following year. If the due date falls on a weekend or holiday, it extends to the next business day.

• December 31 fiscal year end: Due May 15, extended due date November 15
• June 30 fiscal year end: Due November 15, extended due date May 15
• September 30 fiscal year end: Due February 15, extended due date August 15

Need more time? File Form 8868 to request an automatic 6-month extension before your original deadline. Note that Form 990-N deadlines cannot be extended, though there is no penalty for late submission unless it’s your third consecutive missed filing.

Electronic filing requirements

Electronic filing is now mandatory for most nonprofits.

• Form 990-N must always be filed electronically.
• Forms 990 and 990-PF for tax years beginning after July 1, 2019 must be filed electronically; Form 990-EZ must be filed electronically for tax years ending July 31, 2021, and later.
• Form 990-T must be filed electronically for tax years ending December 2020 and later.

Penalties for late or missed filings

Failing to file on time can result in penalties:

• For smaller organizations, the penalty is generally $20 per day, up to the lesser of $10,500 or 5% of gross receipts for the year.
• For larger organizations (those with gross receipts above the IRS threshold for the year), a higher per-day penalty applies and is subject to an annual cap. Amounts are inflation-adjusted annually—see the IRS page for the current figures.
• If a specific individual fails to comply with filing requirements by an IRS-specified date, that person may face penalties of $10 per day, up to $5,000.

Most critically, if your nonprofit fails to file any required form (990, 990-EZ, 990-PF, or 990-N) for three consecutive years, your tax-exempt status will be automatically revoked. Reinstatement after revocation requires reapplying for tax-exempt status and paying the applicable IRS user fee.

While penalties may be abated if you have reasonable cause for filing late, the IRS applies strict standards when evaluating such claims.

Oregon DOJ Annual Filing: Form CT-12 or CT-12F

Beyond federal requirements, Oregon nonprofits must also file annual reports with the Oregon Department of Justice (DOJ) Charitable Activities Section (971-673-1880, doj.state.or.us). This state-level oversight ensures public transparency and proper management of charitable assets within the state. Nonprofits operating in multiple states will appreciate that Labyrinth, Inc. helps monitor varying renewal dates, reporting schedules, and jurisdiction-specific rules across different jurisdictions.

Who must file with the DOJ

The Oregon DOJ requires annual filings from:

• Public benefit nonprofits organized in Oregon
• Out-of-state nonprofits that solicit donations or conduct business in Oregon
• Trusts holding assets in Oregon for charitable beneficiaries
• Associations organized for charitable purposes

Organizations exempt from DOJ registration include:

• Churches and religious organizations
• Oregon mutual benefit nonprofits (provided their purposes aren’t charitable)
• Educational institutions that don’t hold property in Oregon and limit solicitations to alumni

Required attachments and documents

A complete annual report to the DOJ must include:

• The appropriate form (CT-12 for Oregon-based organizations or CT-12F for organizations based outside Oregon)
• A copy of your federal Form 990, 990-EZ, 990-PF, or 5227 with all schedules and attachments
• Copy of any independent auditor’s report and financial statements
• Updates to your registration information, including any legal actions

Organizations that are not required to file an IRS Form 990 may be required by DOJ instructions to provide equivalent financial information for Oregon reporting purposes (e.g., by preparing a federal form for “Oregon purposes only”). We assist nonprofits in organizing filing details, reminders, and agency correspondence to ensure nothing falls through the cracks. For instructions and access, visit the DOJ page to file your annual report.

Fee structure based on revenue

Filing fees operate on a sliding scale based on your organization’s total revenue:

• $0 – $24,999: $20
• $25,000 – $49,999: $50
• $50,000 – $99,999: $90
• $100,000 – $249,999: $150
• $250,000 – $499,999: $200
• $500,000 – $999,999: $300
• $1,000,000 or more: $400

The minimum fee is $20, even if your revenue is zero or negative. Furthermore, if Oregon-specific revenue is $0, you must attach an explanation and indicate whether your organization plans to continue Oregon operations.

How to file and where to send

You have two filing options:

1. Online Portal: The Oregon DOJ offers an online portal where you can submit your report and pay fees via credit card. First-time users must register a new account. All attached documents must be in unsecured PDF format. Access the DOJ’s annual report filing portal.
2. Paper Filing: The DOJ typically mails preprinted forms 2-3 months before your due date. If you don’t receive this form, download it from their website. Mail completed forms with payment to:

Charitable Activities Section
100 SW Market Street
Portland, OR 97201-5702

Your filing is due within 4 months and 15 days after your fiscal year end. Hence, for organizations with a December 31 fiscal year end, reports are due by May 15 of the following year. Labyrinth manages the full renewal process and tracks each deadline to help nonprofits maintain compliance.

Consequences of non-compliance

Failing to file on time triggers automatic late fees that increase the longer a report is delinquent. The Department of Justice may also pursue additional civil penalties against both the organization and its officers/directors for continued non-compliance.

Oregon Secretary of State Annual Report

In addition to IRS and DOJ filings, your Oregon nonprofit must submit an Annual Report to the Oregon Secretary of State’s Corporation Division (503-986-2200, sos.oregon.gov). This filing helps maintain your nonprofit’s active status and ensures your organization’s information remains current in state records. We help nonprofits prepare and submit these required state filings to ensure organizations remain in good standing with state agencies.

Filing process and online portal

All nonprofit Annual Reports must be filed online through the Oregon Business Registry annual report portal. Access your filing in the portal using your Oregon Registry Number and follow the on-screen steps to complete and submit the renewal.

Information required in the report

Your Annual Report must contain several key pieces of information:

• Your nonprofit’s name (cannot be changed during this filing)
• A brief description of your organization’s primary activities
• Your principal office address (where business records are kept)
• Your registered agent’s name and Oregon street address (cannot be a PO Box)
• Names and addresses of current officers (president and secretary)
• At least one member or manager with address

Notably, certain organizational details cannot be modified through the Annual Report. These include changing your nonprofit’s designation (Public Benefit, Mutual Benefit, or Religious corporation) or member status. Such changes require filing separate Articles of Amendment.

Due dates and grace period

Your Annual Report is due on the anniversary date of your original incorporation or registration. The Secretary of State sends renewal notices approximately 45 days before your due date.

What happens if you miss the deadline

If your report is not filed within 45 days after the renewal date, your nonprofit may be administratively dissolved by the Secretary of State. Once administratively dissolved, you’ll need to file for reinstatement and pay a reinstatement fee plus any overdue annual report fees. Reinstatement can be filed online for most entity types if the entity has been dissolved for less than five years; after more than five years, special forms and documentation are required. Learn more about how to reinstate a business in Oregon.

Unrelated Business Income and State Tax Filings

While tax-exempt status shields your nonprofit from many taxes, your organization may still face tax obligations on certain income streams. Understanding unrelated business income tax (UBIT) remains essential for maintaining proper compliance with Oregon’s annual filing requirements.

What qualifies as unrelated business income

Unrelated business income comes from three specific criteria working together:

• Income from a trade or business activity
• That is regularly carried on
• And not substantially related to your nonprofit’s exempt purpose

Even as a tax-exempt organization, your nonprofit can legally make a profit. Nevertheless, when that income derives from activities unrelated to your mission, it becomes subject to taxation. Notably, if your organization generates $1,000 or more in gross unrelated business income, you must report it using IRS Form 990-T.

When to file Form OR-20

You must file Oregon Form OR-20 if:

• Your organization files a federal Form 990-T to report unrelated business income, or
• You have unrelated business taxable income (UBTI) apportioned or allocated to Oregon

Conversely, if you’re exempt from Oregon tax and don’t have any UBTI as defined in Internal Revenue Code Section 512, no Oregon corporation tax return is required. See the Oregon Department of Revenue’s guidance for exempt organizations.

Filing deadlines and methods

Form OR-20 is due on the 15th day of the 5th month following the end of your fiscal year. For calendar-year organizations ending December 31, this means May 15. You may file electronically or by mail, consistent with the Oregon Department of Revenue’s current instructions for Form OR-20. If filing by mail, use the mailing addresses listed in the latest Form OR-20 instructions.

How UBIT affects your nonprofit

An exempt organization filing Oregon Form OR-20 is subject to the greater of:

• Calculated excise tax based on UBTI apportioned to Oregon, or
• Oregon minimum tax

For minimum tax purposes, include in “Oregon sales” only gross unrelated business income apportioned to Oregon. Tax-exempt gross income isn’t included in these calculations.

Remembering these filing requirements helps your nonprofit maintain good standing and avoid potential penalties or complications with your tax-exempt status.

Maintaining Good Standing and Avoiding Penalties

Proactive compliance management helps Oregon nonprofits avoid costly penalties and status issues. Staying on top of your filing requirements saves time, money, and protects your organization’s reputation. Many organizations find that working with experienced compliance specialists helps streamline these administrative responsibilities while ensuring accuracy and timeliness.

Keeping your registered agent updated

Your registered agent serves as your nonprofit’s official point of contact for legal documents. Oregon law mandates maintaining a registered agent with a physical Oregon street address—P.O. boxes are not permitted. Should your agent resign, you have 30 days to designate a replacement or risk administrative dissolution. File changes using the Information Change form through the Oregon Business Registry online portal, and see the Secretary of State’s page on registered agents and service of process.

Updating board and contact information

Board composition and officer requirements are set by Oregon law (ORS Chapter 65). Update officer information during your annual renewal or immediately via the Information Change form. For nonprofits, both president and secretary positions must be listed with current addresses.

Reinstatement after administrative dissolution

If administratively dissolved, you can request reinstatement if your organization’s name remains available. For entities dissolved less than five years, complete this process online or through paper forms with a reinstatement fee plus all missed annual report fees. Entities dissolved beyond five years need special forms and documentation from the Corporation Division. Review the steps to reinstate a business.

Best practices for staying compliant

• Create calendar reminders for all filing deadlines
• Establish clear internal procedures for compliance responsibilities
• Regularly verify your contact information with state agencies
• Document board meeting minutes properly
• Consider professional compliance support to ensure deadlines are met and filings are accurate

Conclusion

Maintaining compliance with Oregon nonprofit annual filing requirements certainly demands attention to detail and consistent follow-through. Throughout this guide, we’ve explored the essential filings your organization must complete each year to remain in good standing with federal and state authorities.

Timely submission of your IRS Form 990 series protects your tax-exempt status, while properly filing your Oregon DOJ CT-12 forms ensures transparency in your charitable operations. Additionally, your Secretary of State Annual Report confirms your nonprofit’s active status in Oregon’s records. Lastly, understanding and reporting any unrelated business income prevents unexpected tax complications.

Missing these deadlines can result in significant consequences. Three consecutive missed IRS filings automatically revoke your tax-exempt status, while overlooked state filings may lead to administrative dissolution and substantial penalty fees. Organizations operating across multiple states face additional complexity in tracking various deadlines and requirements. Therefore, creating a compliance calendar with reminders for each filing deadline becomes essential for your nonprofit’s longevity.

Most importantly, treat these filing requirements as more than just bureaucratic hurdles. Instead, view them as opportunities to review your organization’s financial health, governance practices, and mission alignment. Regular filings actually help your board maintain accountability and demonstrate your commitment to proper stewardship of charitable assets.

Rather than waiting until deadlines approach, consider establishing internal procedures that divide compliance responsibilities among staff or board members. This approach prevents last-minute scrambling and reduces the risk of costly errors or omissions. Many nonprofits also find that dedicated compliance specialists provide valuable support in managing these recurring obligations.

Remember, your nonprofit’s ability to focus on its mission depends on maintaining these fundamental compliance obligations. Though administrative tasks might seem disconnected from your charitable work, they provide the legal foundation that allows your organization to continue serving Oregon communities effectively.

Frequently Asked Questions