Illinois (IL) · Requirement Summary
Illinois 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 Illinois (IL).
| Filing Authority | Illinois Attorney General – Charitable Trusts Bureau. |
|---|---|
| Filing Method | Online Portal – IL AG’s online system for annual reports (or mail forms); some attachments may still be mailed (e.g. checks). |
| Filing Calendar & Triggers | Initial: Prior to soliciting in Illinois (register under Solicitation Act and/or Trust Act). Renewal: Annually – 6 months after fiscal year end (e.g. FYE Dec 31 → Jun 30). Can request one 60-day extension before due date. Late filing incurs $100 fee. |
| Filing Due Date | 6 months after FYE. Example: FYE Dec 31 2025 → Jun 30 2026 due. 60-day extension to Aug 29 2026 available if requested timely. |
| Renewal Detail | Annual report (Form AG 990-IL) + attachments filed to AG. $15 fee if >$15k contributions (no fee if smaller). Report must be signed by two officers. Late: $100 penalty if filed after due without extension. |
| Extensions Calendar | Yes, 60 days: Illinois AG will grant a 60-day extension if a written request is received before the original due date. No further extensions (reports filed after that incur late fees). |
| Exemptions | Very limited: No general small-dollar exemption – even small charities must register (though if ≤$15k contributions, no fee). Only entities exempt: religious organizations (primarily religious purposes), and entities solely holding charitable funds in trust (register under separate Charitable Trust Act). (Political and governmental units are outside the Act’s scope.) |
| Good Standing Required for Charity Filing? | Yes. Illinois requires an “Entity Number” from IL Secretary of State for domestic or foreign corporations on the charity registration. The AG may refuse filings if the organization’s corporate status is inactive. |
| Solicitation while Curing Deficiencies? | Not permitted (high-risk). Illinois treats solicitation without current registration as a violation. If an annual report is late or rejected, the charity is not authorized to solicit until the report is properly filed and accepted. (Timely extension preserves authority during the extension period.) |
| Enforcement Posture | High (Strict). Illinois aggressively enforces filing requirements: late reports incur fees, and the AG can issue cease-solicitation orders for noncompliance. Organizations not filing for multiple years may face injunctions or dissolution. The state has a robust audit program for charitable filings. |
| Recovery Method | Full catch-up. Illinois will not accept a new annual report if prior reports are missing – charities must file the oldest outstanding reports through to the current to regain good standing. Typically up to 3 back years of reports (and fees) may be required to be filed in sequence if the org has been expired. Late penalties ($100 each year) apply. |
| Required Documents | Initial: Form CO-1 registration with Articles of Incorporation/Trust, IRS determination letter, bylaws, and list of officers/trustees; notarized signatures; $15 fee. Annual Report: Form AG 990-IL with two officer signatures, plus IRS Form 990 (Schedules excluding B) attached, and CPA Audited Financials if >$500k contributions (or CPA Review $300k–$500k). Include any required Form IFC for paid fundraisers. |
| Financial Audit/Review Thresholds | >$500,000 contributions: CPA audit report required (threshold raised from $300k in 2024). $300,000–$500,000: CPA review report acceptable. <$300k: no CPA certification needed (small org simplified report). |
| Schedule B Reaction Rule (Donor Names) | Remove. Illinois now instructs “excluding Schedule B” when attaching IRS 990, meaning donor names/addresses should not be submitted. (This is a change; IL previously required the full 990 with Schedule B, but as of 2022 this has been reversed.) |
| Signature Requirements | Two officers (no notary). Illinois Form AG 990-IL must be signed by two different officers (e.g. President and CFO). Notarization is no longer required for annual reports. (Initial CO-1 was historically notarized, but IL is transitioning to e-filing with electronic certification.) |
| High-Risk Traps / Enforcement Notes | – New thresholds (2024): Illinois’ audit threshold increased to $500k and donor disclosure rules changed – organizations should follow the new guidance to avoid rejection (e.g. do not attach Schedule B now). Many filers used to include donor lists and now get flagged for privacy reasons. – Two-officer rule: Illinois mandates two different officer signatures on the AG990-IL. Reports with only one signer (unless a single-trustee trust) will be considered incomplete. – Late fees: Failing to either file or request extension by the due date automatically triggers a $100 late fee – no exceptions. The AG will not accept the report until the fee is paid, compounding delays. |
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