At a Glance

Most nonprofits soliciting donations from Illinois residents must register with the Illinois Attorney General before beginning fundraising activities. Registration requires completing Form CO‑1, paying a $15 fee, and submitting supporting documents including your IRS determination letter and financial statements. Annual reports are due within six months of your fiscal year end to maintain compliance.

Navigating the charity registration process in Illinois can feel overwhelming at first. Many organizations struggle with understanding when they need registration and what steps to follow. Surprisingly, even small nonprofits operating primarily in other states might need to register if they solicit donations from Illinois residents.

Throughout this guide, you’ll discover exactly what documents you need, which forms to file, and how to maintain ongoing compliance with Illinois law. We’ll break down the entire process into manageable steps so you can focus on your mission instead of paperwork. For organizations seeking reliable assistance with nationwide compliance, charitable registration services can handle the entire process from initial filing to annual renewals, ensuring accuracy and timeliness.

Understanding Illinois Charitable Solicitation Laws

The legal framework governing nonprofit fundraising in Illinois establishes clear guidelines for organizations soliciting donations. Charitable entities operating within the state must understand these laws before beginning fundraising activities.

What is charitable solicitation?

In Illinois, charitable solicitation refers to any request for money or property made for charitable purposes. State law defines a “contribution” broadly to include the promise or grant of any money or property of any kind or value. The Act also defines a “charitable organization” as any benevolent, philanthropic, patriotic, or eleemosynary person or entity that solicits and collects funds for charitable purposes. This broad definition encompasses:

• Local, county, or area divisions with authority to disburse funds
• Organizations holding charitable assets
• Entities requesting donations for philanthropic purposes

Experienced compliance specialists who work with charitable registration services often help nonprofits determine whether their activities qualify as solicitation under Illinois law, providing clarity during the initial assessment.

Why registration is required in Illinois

Registration serves multiple important functions in Illinois. First and foremost, it helps establish credibility and transparency in the nonprofit sector. Under the Solicitation for Charity Act, charitable organizations that solicit contributions in Illinois generally must register with the Attorney General before solicitation. In addition, under the Charitable Trust Act, trustees holding property for charitable purposes with a value in excess of $4,000 must register, and registered trustees/organizations must file annual reports.

This framework allows the state to:

1. Protect donors by providing access to financial information
2. Ensure organizations adhere to legal requirements
3. Maintain ethical fundraising practices
4. Enable public verification of an organization’s legitimacy

Additionally, the registration process enables the Attorney General’s Charitable Trust Bureau to effectively oversee nonprofit activities. Through this system, the public can check the online Charitable database to verify if a charity is registered and compliant with reporting requirements.

For organizations seeking guidance through this complex process, working with dedicated nonprofit registration experts ensures proper preparation and filing of all required documentation.

Overview of the Charitable Trust and Solicitation Acts

Illinois has three primary statutes governing charitable organizations: the Charitable Trust Act (760 ILCS 55/1), the Solicitation for Charity Act (225 ILCS 460/1), and Section 17-2 of the Criminal Code (720 ILCS 5/17-2). These laws work together to establish comprehensive oversight of charitable activities.

The Charitable Trust Act primarily regulates trustees holding charitable assets. Under this law, trustees holding property for charitable purposes with a value over $4,000 must register with the Illinois Attorney General and submit periodic annual reports. The Act considers charitable corporate entities, partnerships, and other organizations as charitable trusts in certain contexts.

Conversely, the Solicitation for Charity Act focuses specifically on fundraising activities. This Act requires any charitable organization soliciting contributions within Illinois to register with the Attorney General before beginning solicitation.

Both Acts empower the Attorney General to:

• Establish and maintain registers of trustees and charitable organizations
• Conduct investigations of transactions and relationships
• Make rules and regulations for administration
• Enforce compliance through appropriate legal proceedings

For organizations navigating these complex requirements, partnering with trusted charitable registration service providers simplifies compliance and ensures all legal obligations are met accurately and on time.

The Illinois Attorney General administers these statutes both as a source of public information and as part of fulfilling the common law duty to protect charitable funds. Together, these laws create a framework that promotes transparency while protecting donors and beneficiaries of charitable activities throughout the state.

Who Needs to Register and Who Is Exempt

Understanding who must register for charitable solicitation in Illinois remains essential for nonprofits operating within the state. The Illinois Attorney General’s Office enforces these requirements to maintain transparency and protect donors throughout the fundraising process.

Types of organizations required to register

Nearly all charitable organizations must register with the Illinois Attorney General’s Charitable Trust Bureau prior to solicitation activities, unless specifically exempt. This requirement extends to:

• Nonprofits soliciting contributions from Illinois residents (whether located in Illinois or out of state)
• Anyone soliciting in Illinois on behalf of a nonprofit
• Trustees holding charitable assets in Illinois valued over $4,000 (Charitable Trust Act)

Even out-of-state organizations must comply if they solicit donations from Illinois residents. Many nonprofits turn to specialized charitable registration services to navigate these multi-state requirements effectively and ensure full compliance.

Common exemptions and how to qualify

Illinois law provides several exemptions. Key examples include:

• Small charities receiving no more than $15,000 in contributions during any 12‑month period. These organizations are exempt from annual report filing but still must satisfy the registration requirements of Section 2 to claim the exemption.
• Organizations receiving an allocation from an incorporated community chest or united fund, provided they do not actually receive more than $4,000 from other sources during any 12‑month period ending June 30 and their fundraising is conducted by unpaid persons.
• Appeals for a named individual where all proceeds (minus reasonable expenses for events, if any) benefit that person and all fund‑raising functions are carried out by unpaid persons.
• Bona fide unions and political organizations not soliciting for charitable purposes.
• Fraternal, patriotic, social, educational, alumni organizations, and historical societies when solicitation is confined to their membership.
• Volunteer fire departments (and bona fide auxiliaries or affiliates) whose fundraising is conducted by unpaid members; and organizations operating nurseries for infants awaiting adoption when fundraising is conducted by unpaid members.

Parent‑teacher organizations may also qualify for exemption when they solicit for a particular school and meet specified conditions (including turning over contributions to the school, using only unpaid volunteers, annual contributions within statutory limits, accounting to the school, and school board certification).

For organizations unsure about their exemption status, experienced nonprofit registration experts can provide personalized guidance through the determination process, ensuring proper classification.

Religious and educational institution exemptions

Religious organizations have special treatment in Illinois. To claim the religious exemption from annual report filing, religious groups submit:

• Illinois Form CO‑3 (Religious Organization Exemption Form)
• Form CO‑1 (Charitable Organization Registration Statement)

Educational institutions also receive special consideration. Exempt educational entities include:

• Illinois public universities and schools recognized by the State Board of Education or accredited institutions and foundations affiliated with them
• Schools soliciting donations only from students, alumni, faculty, trustees, and their families
• Libraries established under Illinois law that submit required financial reports

Moreover, fraternal, patriotic, social, and alumni organizations soliciting only from their members may qualify for exemption. Veterans’ organizations chartered under federal law and their recognized affiliates can also operate without registration when statutory conditions are met.

For organizations with complex structures or activities spanning multiple categories, charitable registration professionals can help determine the appropriate classification and navigate the exemption process with confidence.

Given these nuanced requirements, many organizations first verify their status with the Attorney General’s Office or consult with registration specialists to ensure full compliance with Illinois charitable solicitation laws.

Documents and Requirements for Registration

Preparing the proper documentation serves as the foundation for successful charitable solicitation registration in Illinois. The Attorney General’s Charitable Trust Bureau requires specific forms and supporting materials to process your registration completely and efficiently.

IRS Form 990 and financial statements

Complete registration packages typically include a copy of your organization’s most recent IRS Form 990, 990‑EZ, or 990‑PF (excluding Schedule B). If you haven’t filed a federal return, attach a brief explanation.

Financial statements requirements depend on contribution levels and fundraising methods under the Solicitation for Charity Act:

• If annual contributions are more than $300,000 but not more than $500,000 (and you are not otherwise required to file an audited report), submit reviewed financial statements by an independent CPA with your annual report.
• If annual contributions exceed $500,000, submit audited financial statements with your annual report.
• If your fundraising functions are not carried on solely by staff employees or unpaid persons and you receive more than $25,000 in contributions during a 12‑month period, an audited financial statement is required with your annual report regardless of total contributions.

The Act defines “contributions” broadly, including both cash donations and the gross sums paid by the public for merchandise, special events, rights, or services provided by your organization.

Articles of incorporation and bylaws

Your registration package should include copies of your organization’s formation documents. For incorporated entities, this typically includes your Articles of Incorporation; unincorporated associations should submit their constitution with all amendments. All organizations should include their current bylaws.

For out‑of‑state organizations: the Attorney General may request a Certificate of Authority from the Illinois Secretary of State. If your organization is not required to foreign qualify, you may submit a letter explaining why you are not required to register with the Secretary of State.

If you’re planning to apply for federal tax‑exempt status, particularly 501(c)(3) status, the Articles of Incorporation must contain specific language regarding organizational purpose and dissolution. Consulting with nonprofit registration experts can help ensure your documents contain the proper language and meet all requirements.

Professional fundraiser contracts and IRS determination letter

Organizations working with professional fund raisers should include copies of all fundraising contracts with their filings when applicable. Professional fund raisers themselves are required to register using Form PFR‑01 and pay a $100 registration fee. In addition, professional fund raisers must file each active contract and pay a $25 annual filing fee per contract; charities may include copies of those contracts with their filings for transparency.

Your filing should include a copy of your IRS determination letter confirming tax‑exempt status, or if your application is pending, a copy of IRS Form 1023 or 1024.

Special requirements for new organizations

Organizations operational for less than one year typically submit Form CO‑2 Financial Information Form along with their registration. This form collects preliminary financial data since new organizations often lack historical financial reporting.

The registration statement (Form CO‑1) must be signed by the president (or other authorized officer) and the chief fiscal officer. Under the Charitable Trust Act, registration statements are verified under penalty of perjury by two officers or trustees (one signature is accepted if the organization has only one officer or trustee).

All registration materials, including the required $15 registration fee (payable to “Illinois Charity Bureau Fund”), should be submitted together. Failing to register when required can result in civil penalties ranging from $500 to $1,000, along with injunctions and other relief.

Step-by-Step Registration Process in Illinois

Registering your organization for charitable solicitation in Illinois follows a structured process that ensures compliance with state regulations. Let’s explore each step required to successfully complete your registration.

1. Check exemption status

First, determine if your organization qualifies for exemption. Religious organizations submit Form CO‑3 with Form CO‑1 to claim the religious exemption from annual report filing. Educational institutions recognized by the Illinois State Board of Education may qualify for statutory exemptions. Other potential exemptions include small charities receiving no more than $15,000 in contributions during a 12‑month period (exempt from annual report filing but still subject to Section 2 registration) and organizations soliciting only from their members.

2. Provide required contact information (registered agent not required for charity registration)

Illinois charitable solicitation registration does not itself require appointing a registered agent. If your organization foreign qualifies with the Illinois Secretary of State, you will designate a registered agent as part of that process. Otherwise, ensure you provide the required organizational and records contact information on your filing.

3. Complete Form CO‑1 and CO‑2

Prepare Form CO‑1 (Registration Statement) and, if your organization is less than one year old, Form CO‑2 (Financial Information Form). Both forms must be properly signed. New organizations operational for less than one year should submit Form CO‑2 since they typically lack financial history.

4. Submit documents to the Attorney General

Compile all required documentation for submission to the Illinois Attorney General’s Charitable Trust Bureau. Online filing is available through the Illinois Attorney General Charitable Trust Online Filing System (https://charitable.illinoisattorneygeneral.gov/), offering a streamlined submission process. Charitable registration services can ensure your filing meets all requirements and is submitted accurately the first time.

5. Pay the $15 registration fee

Along with your registration materials, include the mandatory $15 registration fee payable to the “Illinois Charity Bureau Fund.” If registration has lapsed or was canceled and you must re‑register, a $200 penalty registration fee applies. Late annual reports are also subject to a $100 late filing fee.

6. Consider using a charitable registration service for comprehensive support

The registration process involves numerous requirements and potential pitfalls. Charitable registration services can manage the entire process on your behalf, providing 1-on-1 guidance from experienced compliance specialists. These professionals ensure all documents are properly prepared, deadlines are met, and your organization maintains good standing with Illinois authorities.

Annual Renewal and Ongoing Compliance

Maintaining compliance after initial charitable solicitation registration requires ongoing attention to renewal requirements in Illinois. The state enforces deadlines and specific documentation to keep your nonprofit’s fundraising authorization active.

Filing Form AG990‑IL

Once registered, your organization must submit Form AG990‑IL (Illinois Charitable Organization Annual Report) to maintain compliance. This comprehensive form requires financial details including revenue summaries, expenditure information, and professional fundraiser activities. The form must be signed by both your organization’s president (or authorized officer) and chief fiscal officer. Remember that incomplete submissions won’t be considered filed.

Renewal deadlines and late fees

Annual reports must be filed within six months after your fiscal year end. For example, if your fiscal year ends December 31, your renewal deadline is June 30. The standard annual report filing fee is $15, payable to the “Illinois Charity Bureau Fund.” Failing to file on time incurs a $100 late fee that must be paid before your report will be accepted. Charitable registration services can track these critical deadlines and ensure timely submission to avoid penalties.

Requesting deadline extensions

You can request a 60‑day extension in writing before your due date. Extensions requested on time are typically granted. If you’ve received a federal IRS extension, you can request an additional extension to match the IRS deadline by submitting documentation of your federal extension along with a draft AG990‑IL and preliminary financials.

How comprehensive renewal management simplifies compliance

Given these requirements, many organizations utilize professional assistance for ongoing compliance management. Labyrinth, Inc.’s charitable registration services provide dedicated renewal management, tracking every deadline and handling form submission through secure client portals. Our expertise helps organizations avoid missed deadlines, incomplete filings, and costly late fees while ensuring continuous good standing.

Additional Compliance Considerations

Professional fundraiser requirements

Organizations working with professional fundraisers face additional compliance obligations. Professional fundraisers must register separately using Form PFR‑01 and pay a $100 registration fee. They must also file each active contract and pay a $25 annual filing fee per contract. Charitable organizations should maintain copies of all fundraising contracts and may include them with their annual reports for transparency.

Financial statement thresholds

As of January 1, 2024, Illinois has updated contribution thresholds that determine financial statement requirements:

• Organizations with annual contributions exceeding $500,000 must submit audited financial statements
• Organizations with contributions between $300,000 and $500,000 must submit reviewed financial statements (unless otherwise required to file audited statements)
• Organizations using professional fundraisers and receiving more than $25,000 in contributions must file audited statements regardless of total contribution amount

These thresholds help ensure appropriate financial oversight based on organizational size and fundraising methods.

Maintaining good standing

To maintain good standing with the Illinois Attorney General, organizations must:

• File annual reports on time
• Pay all required fees promptly
• Update registration information when organizational changes occur
• Respond to Attorney General inquiries or requests for information
• Maintain accurate financial records and documentation

Organizations in good standing can request Letters of Good Standing through the online filing system for use with grant applications or other official purposes.

Conclusion

Navigating Illinois charitable solicitation requirements demands attention to detail and thorough understanding of state regulations. Compliance protects both your nonprofit and the donors who support your cause. Throughout this guide, we’ve outlined each step of the registration process, from determining your exemption status to completing the necessary forms and maintaining annual compliance.

Failing to register when required could result in significant penalties, potentially damaging your organization’s reputation and finances. Therefore, staying proactive about your registration obligations safeguards your nonprofit’s ability to fundraise effectively in Illinois.

Remember that registration requirements don’t end after initial approval. Your organization must submit annual reports and pay renewal fees within deadlines to maintain compliance. Many nonprofits find this ongoing obligation challenging to manage alongside their primary mission activities.

With over 35 years of experience helping nonprofits stay compliant nationwide, professional nonprofit compliance services offer valuable support for organizations seeking reliable, accurate assistance with charitable solicitation requirements. These specialists handle document preparation, deadline tracking, and submission processes, allowing you to focus on your mission rather than administrative paperwork.

Additionally, as regulations change, working with experienced charitable registration experts ensures your nonprofit stays current with all requirements through proactive communication and ongoing guidance. Though registration might seem overwhelming at first, breaking it down into manageable steps makes the process achievable for organizations of any size.

After all, your nonprofit’s ability to solicit donations legally forms the foundation of your fundraising efforts. Proper registration demonstrates transparency and commitment to ethical practices—values that resonate strongly with donors and regulatory authorities alike.

Frequently Asked Questions