At a Glance

Maryland nonprofits must file both federal IRS forms (990 series) and state-specific documents including the Annual Report (Form 1) by April 15 and charitable registration renewals within 6 months of fiscal year-end. Missing these deadlines can result in penalties, loss of tax-exempt status, or charter forfeiture.

Introduction

Managing your Maryland nonprofit’s ongoing compliance doesn’t have to be overwhelming. However, staying on top of these essential paperwork requirements demands attention to detail and proper timing. These filings aren’t just bureaucratic requirements—they’re vital safeguards that protect your tax-exempt status and maintain your organization’s good standing.

With the right guidance, you can navigate both federal and state requirements with confidence. This step-by-step guide specifically focuses on helping your established Maryland nonprofit maintain compliance through proper annual filings—covering everything from Federal Form 990 submissions to Maryland-specific requirements like charitable registration renewals and personal property returns.

What Needs to Be Filed Annually

Managing your nonprofit’s annual filing obligations requires understanding the distinct yet complementary requirements at both federal and state levels. Proper compliance maintains your organization’s legal standing and protects your tax-exempt status.

Federal vs. state filing requirements

At the federal level, the IRS requires all nonprofits to submit annual information returns through the 990 series forms. Which form you file depends on your organization’s size:

• Form 990-N (e-Postcard) for organizations with gross receipts ≤ $50,000
• Form 990-EZ for organizations with gross receipts under $200,000 and total assets under $500,000
• Full Form 990 for larger organizations

These federal returns are due by the 15th day of the 5th month following your fiscal year end, according to the Maryland Comptroller’s nonprofit guidance. For calendar-year organizations, this means May 15th.

In contrast, Maryland state requirements include:

• Annual Report and Personal Property Return (Form 1) due to the Department of Assessments and Taxation by April 15th each year
• Charitable Solicitation Registration renewal, if applicable
• Sales and Use Tax Exemption renewal every five years, per the Maryland Comptroller’s nonprofit guidance

Additionally, organizations with unrelated business income must file both federal Form 990-T and Maryland Form 500 to report and pay taxes on this income, per the Comptroller of Maryland’s nonprofit guidance.

Why annual filings matter for nonprofits

Staying compliant with filing requirements isn’t merely administrative busywork—it directly affects your organization’s operational capacity. Consistent, timely filing:

Preserves your tax-exempt status, allowing you to avoid federal and state income taxes while maintaining donor tax deductions.

Maintains your “good standing” with Maryland authorities. Failure to file the Annual Report could result in forfeiture of your charter or revocation of your registration, as outlined in the Maryland charitable annual update form. We help organizations track these deadlines to ensure submissions remain timely and accurate.

Ensures ongoing fundraising abilities, as current charitable solicitation registration is required before soliciting donations in Maryland.

Creates transparency, thereby building donor trust and organizational credibility.

Common mistakes to avoid

Even experienced nonprofit administrators sometimes stumble with annual filings. Be vigilant about these frequent errors:

Missing critical deadlines. Calendar your filing dates well in advance and consider filing for extensions when needed. Late submissions often trigger penalties—Maryland charges $25 per month for late charitable registration renewals, per the Maryland Comptroller’s nonprofit guidance. Organizations that leverage dedicated compliance specialists often find deadline management becomes more reliable.

Incomplete basic information. A surprising number of filings get rejected due to missing details like legal business name, FEIN, or Department ID numbers. See the SDAT Form 1 instructions.

Incorrect asset classification. When filing Maryland’s Personal Property Return, ensure assets are properly categorized—misclassification may lead to incorrect tax assessments. Refer to the SDAT Form 1 instructions.

Inconsistent information across filings. When filing multiple forms, maintain consistency in your organization’s details across all documents to avoid raising regulatory red flags. The SDAT Form 1 instructions provide helpful guidance.

Overlooking online donation implications. Some organizations fail to realize that having a “donate” button on their website may trigger registration requirements in multiple states.

By understanding both federal and state filing obligations, appreciating their importance, and avoiding common pitfalls, your Maryland nonprofit can maintain compliance year after year, allowing you to focus on your mission rather than regulatory headaches.

Federal Annual Filing Requirements

Even established nonprofits must navigate a complex web of IRS forms to maintain their tax-exempt status. Understanding your federal filing obligations is crucial for avoiding potential penalties.

Form 990, 990-EZ, and 990-N: Which one applies?

The IRS requires every tax-exempt organization to file an annual information return, but which form you’ll submit depends primarily on your organization’s size:

• Form 990-N (e-Postcard): For small organizations with annual gross receipts normally $50,000 or less
• Form 990-EZ: For organizations with gross receipts under $200,000 and total assets under $500,000
• Full Form 990: For larger organizations with gross receipts ≥ $200,000 or total assets ≥ $500,000
• Form 990-PF: Required specifically for private foundations

Note that “gross receipts” refers to the total amounts received from all sources during your accounting period, without subtracting costs or expenses. See the IRS Form 990-N guidance. Organizations eligible for Form 990-N may voluntarily file Form 990-EZ or the full Form 990 instead, but not vice versa.

Deadlines and extensions

Your annual federal form is due on the 15th day of the 5th month after your tax year ends. See the IRS return due dates for exempt organizations. For calendar-year organizations (ending December 31), this means May 15 of the following year, per the IRS Form 990 due date guidance.

Unable to meet the deadline? Form 8868 allows a 6-month automatic extension for Forms 990, 990-EZ, and 990-T. Accordingly, an organization with a December 31 year-end would have until November 15 with an extension, per the IRS due date guidance.

Form 990-N (e-Postcard) filers should note that although there’s no penalty for late filing of this specific form, no extensions are available; see the IRS due date rules for exempt organizations. Furthermore, failing to file any required 990-series form for three consecutive years will automatically result in revocation of your tax-exempt status; see the IRS 990-N guidance.

Unrelated business income and Form 990-T

Despite being tax-exempt, your nonprofit may still need to pay taxes on unrelated business income—revenue from regularly conducted activities not substantially related to your exempt purpose. See the IRS unrelated business income tax guidance.

If your organization has $1,000 or more in gross unrelated business income, you must file Form 990-T in addition to your regular Form 990-series return. This obligation exists regardless of which Form 990 your organization normally files.

• Make quarterly estimated tax payments if expecting tax liability of $500 or more for the year
• Submit these payments by the 15th day of the 4th, 6th, 9th, and 12th months of the tax year
• Ensure payments total 100% of the organization’s tax liability

For Maryland nonprofits specifically, organizations with unrelated business income must also file Maryland Form 500 with the Comptroller of Maryland (410-260-7980, marylandtaxes.gov). This state tax return is due 3.5 months after the end of your fiscal year (March 15 for calendar-year organizations).

Maryland State Filing Requirements

Maryland-based nonprofits face unique state filing obligations beyond their federal requirements. Staying compliant with these state-specific filings ensures your organization maintains its legal status and fundraising privileges throughout the year.

How do I renew my charitable registration?

Organizations soliciting charitable contributions in Maryland must register with the Secretary of State’s Charitable Organizations Division (410-974-5534, sos.maryland.gov) and renew this registration annually. Your registration renewal is due within 6 months after your fiscal year end; see the Maryland charitable annual update form.

The renewal fee structure depends on your organization’s charitable contribution level:

• Less than $25,000: No fee (unless using a Professional Solicitor, then $50)
• $25,000 to $50,000: $50
• $50,001 to $75,000: $75
• $75,001 to $100,000: $100
• $100,001 to $500,000: $200
• Over $500,000: $300 per the Maryland charitable annual update form

Moreover, organizations receiving at least $300,000 but less than $750,000 in charitable contributions must submit a financial review performed by an independent CPA. Organizations receiving $750,000 or more must submit a full audit, as outlined in the Maryland charitable annual update form.

If your organization misses the initial deadline (6 months after fiscal year end), an automatic extension applies until the 15th day of the 11th month after your fiscal year end. Nevertheless, late filings incur a penalty of $25 per month; see the Maryland SOS charitable organizations page. We help organizations track renewal deadlines and manage submissions to ensure compliance while reducing the risk of late penalties.

Annual financial report (Form COF-85)

The COF-85 form serves as an alternative financial report for organizations exempt from filing detailed IRS forms. Typically, you’ll only submit Form COF-85 if your organization:

• Files a 990-N (e-Postcard) with the IRS
• Is exempt from IRS filing requirements entirely

Organizations that file Form 990, 990-EZ, or 990-PF with the IRS should submit a signed copy of that form instead of the COF-85. This submission becomes part of your annual registration renewal package.

For calculating charitable contributions (which determine your fee and audit requirements), the state provides specific guidance on which form lines to include. Generally, this includes direct public support, indirect public support, and revenue from special events; see the Maryland charitable annual update form.

Filing with the Secretary of State

Beyond charitable registration, nonprofits must file Form 1 (Annual Report and Personal Property Tax Return) with the Maryland State Department of Assessments and Taxation (410-767-1184, dat.maryland.gov). This filing is separate from your charitable registration.

Key points about Form 1:

• Due annually by April 15
• Can be filed as early as January 1
• Can be submitted by mail or online
• No filing fee, though late filing may result in penalties if your organization has property in Maryland

The Annual Report must be signed by an officer or principal of your organization. While there’s no fee for the filing itself, failure to submit can result in dissolution or revocation of your nonprofit status.

Organizations affiliated with any Maryland State agency have additional requirements. Those raising more than $750,000 must submit both an audit and an Agreed Upon Procedures Report with their registration; see the Maryland charitable annual update form.

All submissions can be sent to the Charitable Organizations Division via mail (16 Francis Street, Annapolis, MD 21401) or email (dlcharity_sos@maryland.gov). For details, review the Maryland charitable annual update form. For questions regarding these filings, contact the division at 410-974-5534.

State Tax and Regulatory Filings

Beyond charitable registration, Maryland nonprofits must manage several tax-related filings to maintain their exempt status. Keeping track of these requirements ensures your organization avoids penalties and preserves valuable exemptions.

Sales and use tax exemption renewal

Maryland nonprofits holding a sales and use tax exemption certificate must renew this valuable benefit every five years. The renewal cycle operates on a fixed schedule with the next renewal period set for May 2027 for certificates expiring September 30, 2027; see the Maryland Comptroller’s nonprofit guidance.

The renewal process follows this timeline:

• Comptroller’s Office mails renewal notices in May of the renewal year
• Completed applications must be submitted by August 1st
• Failure to meet this deadline may delay issuance of your new certificate

Prior to submitting your renewal application, verify your organization’s name matches exactly with both the IRS records and Maryland Department of Assessment and Taxation (MDAT) listings; see the Comptroller’s guidance for nonprofit exemptions. Organizations must also confirm their good standing status, as this affects eligibility.

For a smooth renewal process, have these items ready:

• Federal Employer Identification Number (FEIN)
• Your current Maryland Sales and Use Tax Exemption Certificate
• Documentation of any name or FEIN changes since last renewal; the Comptroller’s online portal provides application details

Property tax exemption updates

Unlike other exemptions, property tax exemptions for nonprofits typically continue until revoked. Nonetheless, the State Department of Assessments and Taxation conducts periodic reviews to ensure ongoing compliance. Requirements and local provisions may change; consult SDAT and your local jurisdiction for current rules and procedures.

Personal property return (Form 1)

Every Maryland nonprofit must file Form 1 (Annual Report and Personal Property Return) with the State Department of Assessments and Taxation by April 15th each year. See the SDAT Form 1 and instructions. Unlike for-profit entities, nonprofits pay no filing fee for this submission.

The form consists of multiple sections, including basic identification information and, as applicable, a personal property declaration. Use the Form 1 instructions to determine whether you must complete the detailed personal property schedules; small property holdings may qualify for exemptions and some filers may not need to complete all schedules. For questions about eligibility or exemptions, consult SDAT.

Failing to file Form 1 annually by the deadline can result in forfeiture of your organization’s incorporated status, requiring a revival process and additional fees.

Maintaining Compliance Year-Round

Successful compliance with nonprofit annual filing requirements demands year-round attention, not just last-minute scrambling. Establishing effective systems helps you maintain good standing with both federal and state authorities while allowing your team to focus on mission-critical work.

Recordkeeping and documentation

Effective recordkeeping serves as the foundation for timely annual filings. Create a document retention policy that maintains financial records for at least seven years. Throughout the year, systematically collect:

• Financial statements and donation records
• Meeting documentation and board decisions
• Tax-exempt status documentation
• Contracts and grant agreements

For optimal preparedness, maintain separate folders for each filing requirement, gathering relevant documentation as it becomes available throughout the fiscal year. Some organizations find that we help streamline this process through secure document management systems that track deadlines and organize filing details.

Board meeting minutes and bylaws updates

Board minutes function as legal documents that provide evidence your organization exercises proper care in decision-making. These records substantiate that your board operates according to legal requirements, including your own bylaws. Minutes should document:

• Attendance and quorum confirmation
• Key decisions and voting results
• Conflict of interest disclosures
• Mission-aligned activities

Review and update governance documents annually, particularly after significant operational changes. Submit amendments rather than creating entirely new bylaws unless conducting a complete rewrite.

Penalties for late or missed filings

Late or incomplete filings trigger significant consequences. For federal requirements:

• IRS penalties begin at $20 per day for late Form 990 submissions, per the IRS penalty guidelines
• Maximum penalties can reach $10,500 or 5% of gross receipts; see the IRS penalty guidelines
• Missing three consecutive annual filings automatically revokes tax-exempt status; see the IRS penalty guidelines

For Maryland filings:

• Late charitable registration renewals accrue $25 monthly penalties; see the Maryland SOS charitable organizations page
• Repeated annual report non-compliance can result in charter forfeiture

Ultimately, maintaining year-round compliance safeguards both your legal status and organizational reputation.

Conclusion

Managing your Maryland nonprofit’s annual filing requirements demands consistent attention and proactive planning throughout the year. Understanding both federal and state obligations allows you to maintain your tax-exempt status and good standing with regulatory authorities.

The IRS requires your organization to file the appropriate Form 990 series document based on your annual revenue, while Maryland necessitates specific filings including the Annual Report and Personal Property Return (Form 1) and charitable registration renewals. Additionally, you must carefully track deadlines for sales and use tax exemption renewals every five years.

Failing to meet these obligations carries serious consequences. Missing three consecutive federal filings automatically revokes your tax-exempt status, whereas late charitable registrations in Maryland accrue monthly penalties of $25. Therefore, implementing a systematic approach to recordkeeping, documentation, and deadline management proves essential for long-term compliance. Organizations that work with Labyrinth, Inc. often find this administrative burden significantly reduced, as we help track renewal deadlines and manage agency correspondence, allowing leadership to concentrate on advancing their mission.

Remember that these filing requirements protect more than just your legal status—they safeguard donor trust and your organization’s reputation. Treating compliance as an ongoing responsibility rather than a yearly inconvenience will help your nonprofit focus on its mission without regulatory interruptions.

Your Maryland nonprofit can thrive when you establish reliable systems for tracking deadlines, maintaining thorough records, and ensuring timely submissions. Above all, staying informed about changing requirements and addressing them promptly will keep your organization’s operations running smoothly for years to come.

Frequently Asked Questions