Illinois Charitable Solicitation Registration Compliance Checklist
TLDR
Illinois requires charitable organizations to register under two parallel statutes — the Charitable Trust Act and the Solicitation for Charity Act — both administered by the Attorney General's Charitable Trust Bureau. Initial registration uses Form CO-1 with the financial schedule on Form CO-2, and annual filing uses Form AG990-IL. This checklist covers initial registration, annual reporting, the audit threshold for organizations over $300,000 in revenue, professional fundraiser rules, and dissolution procedure.
Why Illinois Has Two Statutes
Illinois historically separated charitable trusts (gifts and bequests held in trust for charitable purposes) from charitable solicitations (active fundraising appeals). The Charitable Trust Act regulates the former; the Solicitation for Charity Act regulates the latter. Most modern public charities engage in both — accepting gifts that fund their charitable purpose AND soliciting contributions. So most public charities must register under both statutes.
The Attorney General’s Charitable Trust Bureau administers both through a single registration process. One CO-1 filing covers both statutes, with separate fees and reporting components. This is administratively efficient but legally significant: enforcement actions can be brought under either or both statutes, depending on the conduct.
Step 1: Confirm Registration Triggers
- Charitable Trust Act applies if the organization holds property or assets in Illinois for charitable purposes — including a 501(c)(3) bank account, real estate, or pledged contributions.
- Solicitation for Charity Act applies if the organization solicits contributions in Illinois — including direct mail, online appeals targeting Illinois residents, telephone, or in-person solicitation.
- Out-of-state organizations soliciting Illinois residents must register under the Solicitation for Charity Act.
- Statutory exemptions exist for religious organizations, accredited educational institutions, governmental entities, and certain veteran groups. Most 501(c)(3) public charities are not exempt.
Illinois Charitable Solicitation Registration Compliance Checklist
A practical checklist for Illinois charitable registration — Form CO-1 initial filing, Form CO-2 financial information, the AG990-IL annual report. Delivered by email.
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