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New York Charitable Solicitation Registration Compliance Checklist

Published: Last updated: Reviewed: Sources: charitiesnys.com charitiesnys.com charitiesnys.com ag.ny.gov

TLDR

New York runs the strictest dual registration regime in the country. Charities must register with both the Attorney General's Charities Bureau (under Executive Law Article 7-A and Estates, Powers & Trusts Law Section 8-1.4) before soliciting, and they must file the annual CHAR500 with mandatory CPA review at $250,000 in revenue or full audit at $1,000,000. This checklist covers initial registration on CHAR410, annual CHAR500 renewal, the financial reporting tiers, and the closeout obligations under the Nonprofit Revitalization Act of 2013.

New York’s Dual Statutory Framework

Two separate New York statutes regulate charitable organizations, and most charities are subject to both:

  • Executive Law Article 7-A governs charitable solicitation. It applies to any organization that solicits contributions in New York.
  • Estates, Powers & Trusts Law (EPTL) Section 8-1.4 governs charitable trusts and most charitable corporations.

The Charities Bureau administers both. A single registration covers both statutes, and the CHAR410 / CHAR500 forms have separate sections for each. This dual framework is why New York is more demanding than states with a single charitable solicitation regime — even charities that do not solicit may still need to register under EPTL.

Step 1: Confirm Registration Triggers

  • Article 7-A registration is required if the organization solicits contributions from New York residents — including online appeals targeting NY donors, direct mail, telephone, and in-person solicitation.
  • EPTL registration is required if the organization is incorporated under NY Not-for-Profit Corporation Law, holds assets in trust for charitable purposes in New York, or has its principal office in New York.
  • Identify exemptions. Article 7-A exempts religious organizations, certain educational institutions registered with the NY Education Department, parent-teacher associations, and certain veteran groups. Most 501(c)(3) public charities are not exempt.
  • Out-of-state organizations soliciting NY residents must register under Article 7-A regardless of where they are incorporated.

New York Charitable Solicitation Registration Compliance Checklist

A practical checklist for New York charitable registration — the CHAR410 initial filing, annual CHAR500 renewal, the $250,000 CPA review threshold. Delivered by email.

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Frequently asked

Frequently Asked Questions

Who must register with the New York Attorney General?
Any organization that solicits contributions in New York, holds property in trust for charitable purposes, or is incorporated as a New York not-for-profit must register with the Attorney General's Charities Bureau before soliciting.
What is the difference between CHAR410 and CHAR500?
CHAR410 is the initial registration filed once. CHAR500 is the Annual Financial Report filed every year thereafter. Both are filed online through the Charities Bureau e-filing portal.
When does New York require a CPA review or audit?
Article 7-A organizations with gross revenue over $250,000 must submit a CPA-reviewed financial statement. Organizations over $1,000,000 must submit a CPA audit.
When is the CHAR500 due?
Four months and 15 days after the close of the organization's fiscal year — May 15 for calendar-year filers. A 180-day extension is available by filing CHAR500 with extension request before the original due date.
What is the Nonprofit Revitalization Act?
The Nonprofit Revitalization Act of 2013 modernized New York's nonprofit law and added governance requirements including written conflict-of-interest policies, whistleblower policies for organizations with 20+ employees and $1M+ revenue, and independent audit committee oversight at the audit threshold.
Are there penalties for late filing?
Yes. Late fees start at $25 per late filing and the Charities Bureau can suspend registration. Suspended organizations cannot legally solicit in New York and may be flagged on the public registry search.