California (CA) · Requirement Summary
California charitable solicitation requirements summary
A compact operational summary pulled from our Master State Requirements (MSR). Use this as a quick reference for filing authority, cadence, documents, and common traps.
Requirement Summary
Key requirements for California (CA).
| Filing Authority | California Attorney General – Registry of Charitable Trusts. |
|---|---|
| Filing Method | Online – Registry’s e-portal for Form RRF-1 and attachments (email/paper if exempt from e-filing). |
| Filing Calendar & Triggers | Initial: Before soliciting or holding assets in CA. Renewal: Annually by 4 months +15 days after fiscal year end (matches IRS 990 due date). Auto-extends if IRS grants extension. |
| Filing Due Date | 4 mo +15 days after FYE (automatic extension to IRS date if Form 8868 filed). Example: FYE Dec 31 → May 15 (or Nov 15 if IRS extended). |
| Renewal Detail | Annual renewal (Form RRF-1) filed with Registry of Charitable Trusts along with copy of IRS Form 990 (minus donor names). $25 fee if revenue ≥$50,000 (scaled by revenue) per schedule. |
| Extensions Calendar | Automatic if IRS extended: California renewal due date automatically follows any IRS Form 990 extension (no separate request needed). Additional state-specific extension not required. |
| Exemptions | Limited: No broad revenue exemption – most 501(c)(3) orgs must register. (Only religious organizations, hospitals, and educational institutions are exempt by statute.) Schedule B donor names not required as of 2021. |
| Good Standing Required for Charity Filing? | Yes. Charity must be properly incorporated (active status) in home state and in CA if operating as foreign. CA AG may suspend charities that are not in good standing with CA Sec. of State. |
| Solicitation while Curing Deficiencies? | Not permitted. California law requires a valid registration to solicit. If a renewal is delinquent or “cure period” ongoing, the charity should suspend solicitations until the Registry is back to “current” status. |
| Enforcement Posture | High. California has a strict stance – the AG can issue fines, suspend delinquent organizations, and disallow fundraising until compliance. Frequent delinquency sweeps and penalty assessments ($200 per missed report) for late filings are conducted. |
| Recovery Method | Back-fill required; penalties possible. California requires delinquent charities to file all missed annual reports (RRF-1) for each year of lapse. A charity must submit past-due RRF-1s and 990s to restore good standing, and the AG may impose late fees or penalties for the gap period. |
| Required Documents | Initial: Form CT-1 and $25 fee, with founding documents (articles, bylaws) and IRS determination letter. Renewal: Form RRF-1 and $25 fee (if applicable) with a copy of IRS Form 990 (with Schedule B donors removed). If gross revenue ≥$2M, attach audited financial statements. |
| Financial Audit/Review Thresholds | ≥$2,000,000: CPA audit required (per CA Govt. Code §12586). No CPA review tier (only full audit if ≥$2M). |
| Schedule B Reaction Rule (Donor Names) | Remove. California no longer collects Schedule B donor information – charities should exclude donor names from any 990 submitted (per AFPF v. Bonta ruling). Schedule B is kept confidential if provided. |
| Signature Requirements | Authorized e-sign. California accepts electronic signatures on online filings. No notarization or multiple signers required (one officer or trustee can sign forms). |
| High-Risk Traps / Enforcement Notes | – Dual filings: CA nonprofits must file both with the AG (Registry) and with CA Franchise Tax Board if applicable (for state tax purposes). – Penalties: California imposes $200 late fees for delinquent reports and can suspend an org’s registration (making solicitation illegal). Repeat non-filers may face cease and desist orders or loss of state tax exemption. – Schedule B: Do not include donor names; including them is a privacy violation post-Bonta. |
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