Michigan CTS-02 Charitable Registration Compliance Checklist
TLDR
Michigan nonprofits face three recurring compliance touchpoints: registering with the Michigan Attorney General Charitable Trust Section, filing the CTS-02 Annual Financial Report on schedule, and clearing the state audit threshold ($525,000 in contributions (CPA review); $550,000 (CPA audit) under MCL 400.273). This checklist walks through initial registration, the annual renewal cadence (30 days after IRS Form 990 due date (typically November 15 for calendar filers)), required attachments, fee tiers (No renewal fee), common rejection reasons, and the closeout steps when activity in Michigan ends. Pulled from MCL 400.271 et seq. (Charitable Organizations and Solicitations Act) and the Michigan AG Charitable Trust Section portal at https://www.michigan.gov/ag/initiatives/charitable-trust.
Why Michigan Compliance Is Worth Calendaring Now
Two-tiered financial review thresholds - review at $525K, audit at $550K - surprise organizations crossing the line mid-year. Every Michigan nonprofit that solicits contributions has the same three obligations: an initial registration filed before solicitation begins, a recurring CTS-02 Annual Financial Report renewal at the cadence the Michigan Attorney General Charitable Trust Section 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 Michigan is MCL 400.271 et seq. (Charitable Organizations and Solicitations Act). The administrative portal is https://www.michigan.gov/ag/initiatives/charitable-trust. 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 Michigan nonprofit software overview.
Step 1: Confirm Whether You Must Register
- Determine the registration trigger. Most Michigan 501(c)(3) charities that solicit contributions from Michigan residents must register with the Michigan Attorney General Charitable Trust Section under MCL 400.271 et seq. (Charitable Organizations and Solicitations Act).
- 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 Michigan AG Charitable Trust Section; others apply automatically but still require records if questioned.
- Confirm out-of-state solicitation rules. A nonprofit headquartered outside Michigan that runs an email campaign or direct mail to Michigan residents is generally soliciting in Michigan for registration purposes.
Michigan CTS-02 Charitable Registration Compliance Checklist
A practical compliance checklist for Michigan nonprofits covering CTS-02 Annual Financial Report filings with the Michigan Attorney General Charitable Trust Delivered by email.
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Q&A
What state agency regulates nonprofit charitable solicitation in Michigan?
The Michigan Attorney General Charitable Trust Section regulates charitable solicitation in Michigan under MCL 400.271 et seq. (Charitable Organizations and Solicitations Act). Filings are submitted through https://www.michigan.gov/ag/initiatives/charitable-trust.
Q&A
What is the deadline for the CTS-02 Annual Financial Report?
30 days after IRS Form 990 due date (typically November 15 for calendar filers). Calendar this date the day registration is approved - most missed renewals trace back to the deadline never being entered into a shared calendar.
Q&A
How much does Michigan charitable registration cost?
Initial registration is No initial registration fee. Annual renewal is No renewal fee. Confirm tier on the Michigan AG Charitable Trust Section fee schedule.
Q&A
When does Michigan require an independent CPA audit?
$525,000 in contributions (CPA review); $550,000 (CPA audit) under MCL 400.273. Engage a CPA firm before fiscal year end if you are within 10% of the threshold - audit engagements typically take 60-120 days.
Q&A
What attachments are required with the CTS-02 Annual Financial Report?
Most Michigan renewals require IRS Form 990 (or 990-EZ/990-PF), a list of officers and directors, and the financial schedule appropriate to your gross revenue tier. Audited statements are required at the audit threshold.
Frequently asked