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California Charitable Solicitation Registration Compliance Checklist

Published: Last updated: Reviewed: Sources: oag.ca.gov oag.ca.gov oag.ca.gov oag.ca.gov

TLDR

California requires every charity that solicits or holds assets in the state to register with the Attorney General's Registry of Charitable Trusts before any fundraising occurs. This checklist covers initial registration on Form CT-1, annual RRF-1 filings, the $25,000 gross-revenue threshold that triggers the financial reporting schedule, the $2 million audit requirement under the Nonprofit Integrity Act, and the closeout obligations when activity in California ends.

Why California Registration Is Stricter Than Most States

California has the most active charity oversight regime in the country. The Registry of Charitable Trusts, run by the Attorney General’s Charitable Trusts Section, registers approximately 100,000 organizations and pursues enforcement actions against hundreds each year. Penalties for late filings, missed audits, and unregistered solicitation are real — and they compound quickly.

If your organization is incorporated in California, raises money from California residents, or holds property in trust for charitable purposes within the state, you are required to register before you solicit a single dollar. The 30-day initial registration window starts when you first receive property — including your initial board contributions or seed funding.

This checklist walks through registration, annual renewal, the financial reporting tiers, the $2 million audit trigger, and the closeout steps when you stop operating in California.

Step 1: Determine Whether You Must Register

  • Confirm registration triggers. You must register if your organization (a) is incorporated in California, (b) holds assets or property in California for charitable purposes, or (c) solicits contributions from California residents — including online solicitation that targets California donors.
  • Check exemption categories. Review Government Code Section 12583. Religious organizations, accredited schools, hospitals, and certain government-affiliated entities are exempt. Most 501(c)(3) public charities are not.
  • Document your basis for any claimed exemption. If you believe you are exempt, keep written documentation of the exemption category and the supporting facts. Exemption is not self-evident on its face — you may need to defend it.

California Charitable Solicitation Registration Compliance Checklist

A practical checklist for registering and maintaining charitable solicitation status in California. Delivered by email.

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Frequently asked

Frequently Asked Questions

Who must register with the California Attorney General?
Any charitable corporation, unincorporated association, or trustee that holds assets or solicits contributions in California must register within 30 days of first receiving property. This includes out-of-state nonprofits soliciting California residents.
What is Form RRF-1 and when is it due?
Form RRF-1 is the Annual Registration Renewal Fee Report filed with the Registry of Charitable Trusts. It is due 4 months and 15 days after the close of the organization's fiscal year — May 15 for calendar-year filers.
When does California require an audited financial statement?
Under the Nonprofit Integrity Act of 2004, charitable organizations with gross revenue of $2 million or more (excluding government grants with required accounting) must have an independent CPA audit and file it with the RRF-1.
What is the solicitation threshold for filing financial schedules?
Organizations with gross revenue of $50,000 or more must submit IRS Form 990 or 990-EZ with the RRF-1. Organizations under $50,000 gross revenue file Form CT-TR-1 instead.
What happens if a charity solicits before registering?
The Attorney General can issue cease-and-desist letters, assess late fees, and pursue civil penalties under Government Code Section 12591. Donors may also be entitled to refunds for contributions solicited unlawfully.
Are there exemptions from California registration?
Government agencies, religious organizations holding property exclusively for religious purposes, accredited educational institutions, hospitals, and certain cemetery corporations are exempt under Government Code Section 12583.