November 15 is an important date for renewing charitable solicitation registrations. Many states base their charitable solicitation renewal and annual financial reporting due dates on the charity’s fiscal year. Upon filing with the state charitable solicitation authorities, charities must usually submit a copy of their most recent federal 990 return and financial statements, as applicable.
Form 990 (and its variations), without any extensions, is due to the IRS four months and fifteen days after the close of a charity’s fiscal year. Many states have adopted this same schedule for their individual charitable solicitation renewal and annual financial reporting requirements. This can cause a massive scramble to meet nationwide deadlines for charities of all sizes.
Due to this schedule, November 15 is one of the most common due dates (May 15 is another). Renewing charitable registrations on time is critical to avoiding state penalties and staying in compliance. There are a few common situations in which organizations would renew in November:
The following states require charities to file a renewal prior to four months and fifteen days after the end of the fiscal year. For charities with a June 30 fiscal year end, that would be November 15:
In addition, Michigan will be due on November 30. Charities whose 990 and financial statements will not be complete prior to the above deadlines can often file with each state to obtain an extension of time to file. In most cases, this is a separate and additional task from filing extensions with the IRS (Form 8868).
If your charity has filed two Form 8868 extensions with the IRS, and also filed extensions with the above states, your new due date to file Form 990 and state-specific annual financial reports is generally November 15. Be aware, in some states, you may still be required to submit other registration information prior to November 15.
Pennsylvania has eliminated this headache, and requires charities to renew their registration prior to ten months and fifteen days after the end of the fiscal year. For charities on a December 31st fiscal year end, that due date is November 15 by default. In addition, Connecticut and Washington will be due on or before November 30.
Regardless of fiscal year end, Maine requires charities to file a renewal and annual financial report before November 30.
In some states, like Florida, charities may have filings due in November based on the anniversary of their initial registrations. Factoring in these dates is necessary to successfully managing the renewal filing requirements.