Illinois nonprofits register with the Attorney General's Charitable Trust Bureau (initial CO-1 / CO-2) and file the AG990-IL annual report on a six-month-after-fiscal-year-end cadence. The Bureau's audit threshold and the Illinois Charitable Solicitation Act create a layered compliance picture that does not perfectly align with federal Form 990 timing — most filing failures here are calendaring errors rather than substantive issues.
A Chicago-area youth services nonprofit hit $310,000 in annual contributions for the first time, crossing the Illinois audit threshold. The AG990-IL was filed on the standard six-month-after-fiscal-year-end cadence — but without the audited financial statement that should now have been attached. The Charitable Trust Bureau flagged the filing as incomplete, and a state contract scheduled for renewal was put on hold until the audit was produced and re-submitted. The organization spent the next ten weeks contracting an auditor, paying expedited fieldwork fees, and re-filing — fees that exceeded the budget for that year’s audit by roughly 40%.
Illinois compliance has three layers that often get conflated: the federal Form 990, the Illinois Attorney General’s AG990-IL, and the Illinois Secretary of State annual report. They run on different calendars, go to different agencies, and require different supporting material. Federally funded Illinois nonprofits add a fourth layer when single-audit thresholds are crossed — see the practical guide to 2 CFR 200.
The 12 questions below cover the cadence, audit thresholds, the CO-1/CO-2 distinction, and the cross-cutting points where state and federal compliance interact. For Chicago-specific funder ecosystems, see the Chicago foundation grants guide. For the federal compliance baseline, see the grant compliance FAQ and the single audit FAQ.
Implementation realities and migration notes
Mid-sized nonprofits in this category typically inherit a tangle of restricted-fund histories: federal pass-throughs, state agency contracts, family-foundation grants, and partner funding stretching back many years. Migrating that history cleanly is not optional — auditors and program officers will ask questions that require a year-by-year reconstruction. Implementation timelines run six to ten weeks for organizations that scope the data inventory before signing. Cutting corners on migration to chase a fast launch usually surfaces gaps during the next single-audit cycle, and the cost of fixing those gaps after the fact is meaningfully higher than doing migration right at the start.
Plan accordingly, and require any vendor on the shortlist to demonstrate restricted-fund handling, grant tracking, and donor record migration on a representative sample of your actual historical data before you sign. Vendors that decline to demo on real data are filtering you out for a reason. The demo on your data is where the gaps surface — both the gaps in the vendor’s product and the gaps in your existing records that you will need to clean up regardless of which system you choose. Use that demo to set realistic expectations with the board and the audit committee about timeline and scope before contracts get signed.
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Approximately 75,000 active 501(c)(3) public charities are registered with the IRS in Illinois as of recent BMF extracts.
Why does Illinois have a longer AG990-IL filing window than the federal 990?
Illinois designed AG990-IL to be filed after the 990 is finalized, recognizing that state registration requires accurate annual financial data that may not be ready by the federal deadline. The longer window is a feature, not an oversight — but it does mean two separate calendar dates need tracking.
Q&A
Are private foundations subject to AG990-IL?
Yes. Private foundations holding charitable assets in Illinois register under the Charitable Trust Act and file AG990-IL. The form attaches Form 990-PF rather than Form 990.
Q&A
Does the Illinois AG investigate complaints against nonprofits?
Yes. The Charitable Trust Bureau investigates complaints involving misuse of charitable assets, deceptive solicitation, and breach of fiduciary duty by directors and trustees. Investigations can result in restitution orders, civil penalties, and removal of officers.
Frequently asked
Frequently Asked Questions
Who has to register with the Illinois AG Charitable Trust Bureau?
Any organization holding charitable assets in Illinois or soliciting charitable contributions from Illinois residents must register with the Illinois Attorney General's Charitable Trust Bureau under the Charitable Trust Act and the Solicitation for Charity Act. Initial registration uses Form CO-1 (Charitable Trust Registration) or CO-2 (Charitable Solicitation Registration) — most organizations file both. Out-of-state organizations soliciting Illinois donors are subject to the same registration requirements as Illinois-incorporated organizations.
When is AG990-IL due?
AG990-IL is due 6 months after fiscal year end. For a calendar-year nonprofit, that is June 30 — two months later than the federal Form 990 (without extension). Illinois grants extensions of up to 60 days on request. The longer state cadence is a common source of confusion: organizations sometimes file AG990-IL early to align with the 990 deadline and then face follow-up requests when the financials change between draft and final.
When does Illinois require an audit attached to AG990-IL?
Under the Solicitation for Charity Act, organizations with annual contributions of $300,000 or more must attach an audited financial statement prepared by an independent CPA. Organizations with annual contributions between $25,000 and $300,000 must attach a CPA review or audit if professional fundraisers are used; otherwise, financial statements prepared by an independent CPA are sufficient. Below $25,000, no professional preparation is required. Verify current thresholds on the AG site at illinoisattorneygeneral.gov/charities — these have moved historically.
What is the difference between CO-1 and CO-2?
CO-1 is the Charitable Trust Registration form, used by organizations holding charitable assets in Illinois (the trust law track). CO-2 is the Charitable Solicitation Registration form, used by organizations soliciting contributions from Illinois residents. Most operating nonprofits file both because they hold assets and solicit. The two registrations are administered by the same Charitable Trust Bureau and renewed via the same AG990-IL annual filing.
How does Illinois Form CO-3 fit in?
Form CO-3 is used by professional fundraising consultants and fundraisers operating in Illinois. The nonprofit does not file CO-3 directly, but if your organization contracts a professional fundraiser, that fundraiser must be registered separately, and your AG990-IL must list the fundraisers used and the contracts in effect. Mismatches between the nonprofit's reported fundraisers and the fundraisers' own filings are a common audit trigger.
What annual filings does my Illinois nonprofit need with the Secretary of State?
Illinois requires every nonprofit corporation to file an annual report with the Secretary of State, separate from AG990-IL. The Secretary of State annual report is due before the first day of the corporation's anniversary month (the month of original incorporation). It is a different form, paid to a different agency, with different timing — most Illinois nonprofits file two state-level annual filings per year (Secretary of State annual report + AG Charitable Trust Bureau AG990-IL).
How does Illinois interact with the federal single audit?
Illinois pass-through dollars in many state-administered programs (DCFS, IDPH, ICCB, ISBE) flow federal funds and trigger Uniform Guidance on the subrecipient. If your federal expenditures aggregate to $1,000,000 or more in a fiscal year, you must conduct a single audit under 2 CFR 200 Subpart F regardless of the agency administering the funds. Illinois state-only contracts do not count toward the threshold, but state administration of federal pass-through funds does. Reconcile your SEFA carefully — distinguishing state-only from federal pass-through in Illinois can require contacting the awarding state agency.
What is the Illinois Charitable Trust Act and how does it differ from the Solicitation for Charity Act?
The Charitable Trust Act (760 ILCS 55) governs organizations holding charitable assets in Illinois — registration via CO-1, ongoing reporting on AG990-IL, fiduciary obligations of trustees and directors. The Solicitation for Charity Act (225 ILCS 460) governs the act of soliciting charitable contributions in Illinois — registration via CO-2, disclosures required during solicitation, oversight of professional fundraisers. Most nonprofits are subject to both Acts simultaneously.
What happens if my AG990-IL is late?
Late filing of AG990-IL results in delinquent status with the Charitable Trust Bureau, publicly visible on the AG charitable database. The Bureau assesses late fees and may suspend or revoke registration in cases of continued non-compliance. Suspension of registration suspends the legal authority to solicit in Illinois. Foundation due diligence routinely checks AG charitable status — a delinquency flag affects funding decisions before you know it has been pulled.
Does Illinois require me to file a copy of the federal 990?
Yes. AG990-IL requires submission of a complete copy of the most recent federal Form 990 (or 990-EZ), and most of the financial detail in AG990-IL flows directly from 990 line items. Discrepancies between the two filings — different total revenue, different program expenses — are an automatic flag. Plan to complete and reconcile the 990 first, then build AG990-IL from the same numbers.
What records does the Charitable Trust Bureau expect me to maintain?
Illinois requires registered organizations to maintain books and records sufficient to document all charitable contributions received and disbursed, including donor records, fundraiser contracts, board minutes, and financial statements. Records should be retained for the period required by federal law (three years from final 990 / final expenditure report at minimum) and for any period required by state contracts or grants. The AG can request records during examination — disorganized records prolong examination and increase the likelihood of follow-up enforcement.
How do I withdraw an Illinois charitable registration?
To withdraw, file a final AG990-IL marked as final, submit a written request for withdrawal to the Charitable Trust Bureau, and resolve any outstanding fees, late filings, or disclosure issues. Illinois nonprofits dissolving the corporate entity must also file dissolution articles with the Secretary of State and follow the wind-up procedures of the Illinois General Not For Profit Corporation Act, including charitable asset distribution per the cy près doctrine.
