New York Charitable Solicitation Registration Compliance Checklist
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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