Coronavirus and Charity Registrations: Update for April 7, 2020

Posted on April 7, 2020 by John Beck in Nonprofit Compliance.

State charity offices have been making rapid responses to the COVID-19 pandemic. Now concerned with the promotion of public health, these officials are taking steps that impact your nonprofit’s state registrations. In the interest of our keeping clients informed, we are sharing these updates with you.

IRS Form 990 deadline is still May 15, 2020 for most organizations

As of this article, the deadline for Form 990, 990-EZ, 990-PF, and 990-N is still May 15, 2020. This applies to organizations with tax years ending December 31, 2019 and June 30, 2019. 

This deadline is in contrast to individual, business income, and 990-T returns. The IRS has granted an extension for filing these returns from April 15 to July 15, 2020. 

To assist organizations and taxpayers, the IRS maintains a current page of Filing and Payment Deadlines. Review this resource periodically to see if your organization qualifies for relief.

States grant additional time to file charitable registration renewals

The Pennsylvania Department of State is granting relief to organizations with renewal deadlines falling between April 30, 2020 and July 31, 2020. Below are the extended deadlines for Form BCO-10:

The Minnesota Attorney General, already behind on its backlog of state charity registration applications, is granting an automatic 4-month extension for any filings due between April 15 and July 15, 2020. No separate request is required. Below are the extended due dates for Minnesota charity renewal registrations:

The Ohio Attorney General has granted a due date for nonprofits whose fiscal year ends May 31. Normally, the due date is April 15, 2020. This has been extended until June 1, 2020.

The corporation divisions of the following states have extended their deadline for corporate annual reports:

  • District of Columbia – biennial statements extended until June 30 without penalty
  • Florida – annual reports extended until June 30, 2020, without penalty
  • Maryland – personal property tax reports extended until July 15 without penalty

States relax signature requirements on charitable registration forms

The state of Georgia has temporarily suspended the need for notarized signatures on Form C-100 and select charitable registration forms.

New Hampshire is temporarily accepting scanned, notarized signatures on its annual registration forms.

The California Franchise Tax Board, which historically required wet, original ink signatures, is temporarily accepting photocopied (scanned) signatures.

Arkansas, North Carolina, and West Virginia still require notarized signatures at this time.

State charity office closures

Many state agencies are working remotely or are closed altogether, including:

  • Connecticut
  • Hawaii
  • Illinois
  • Maryland
  • Massachusetts
  • Mississippi
  • New Jersey
  • New Mexico
  • New York
  • Oregon
  • Pennsylvania
  • Rhode Island
  • South Carolina
  • Virginia

Our team is in regular contact with state agencies. We will update this list as additional state offices move offline. Even if a state is not listed, unforeseen delays may occur.

Mailed applications to these agencies will not be processed quickly or may even be returned. Approval letters may be significantly delayed. Where online filing exists, it is generally the better option. Be patient during this time!

For more updates, subscribe to our email list. If you need assistance managing your state charity registrations, contact us.

From all of us at Harbor Compliance, stay tuned and stay safe during these challenging times.


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