Maryland COF-85 Charitable Registration Compliance Checklist

Why Maryland Compliance Is Worth Calendaring Now

Maryland accepts the Unified Registration Statement (URS) as an alternative to its own initial registration form. Every Maryland nonprofit that solicits contributions has the same three obligations: an initial registration filed before solicitation begins, a recurring COF-85 Annual Update of Registration renewal at the cadence the Maryland Secretary of State Charity Division sets, and the financial schedules and disclosures the statute requires. None of those are dramatic on their own. They become dramatic when one slips and a foundation grantmaker checks public registry status before approving an award.

The governing law in Maryland is Md. Code, Bus. Reg. § 6-101 et seq.. The administrative portal is https://sos.maryland.gov/Charity/Pages/default.aspx. Fees, deadlines, and forms can change between fiscal years - confirm against the source before each cycle.

This checklist is structured the way the work actually flows: confirm your registration trigger, complete the initial registration, calendar the recurring renewal, manage the audit threshold, and handle closeout. Each step links to the form name and authority so you can hand it to a colleague without re-explaining context. For broader grant compliance scope beyond charitable registration, see our Grant Compliance 101 for Nonprofits guide and the Maryland nonprofit software overview.

Step 1: Confirm Whether You Must Register

• Determine the registration trigger. Most Maryland 501(c)(3) charities that solicit contributions from Maryland residents must register with the Maryland Secretary of State Charity Division under Md. Code, Bus. Reg. § 6-101 et seq..
• Check exemption categories. Religious organizations, accredited educational institutions, certain government-affiliated entities, and small organizations under specific revenue thresholds may be exempt. Read the statute, do not rely on assumption.
• Document any claimed exemption. If you believe you are exempt, keep written documentation of the category and supporting facts. Some exemptions require an affirmative filing with the Maryland Charity Division; others apply automatically but still require records if questioned.
• Confirm out-of-state solicitation rules. A nonprofit headquartered outside Maryland that runs an email campaign or direct mail to Maryland residents is generally soliciting in Maryland for registration purposes.