New York nonprofits operate under three overlapping compliance regimes — the New York State Attorney General's Charities Bureau (CHAR500), the New York Department of State, and city-level requirements from the NYC Department of Consumer and Worker Protection (DCWP) for fundraising activity and the NYC Department of Health and Mental Hygiene (DOHMH) for any human services contracting. Missing one of the city filings does not relieve you of the state filing, and vice versa.
A New York City community arts nonprofit with $1.4M in revenue thought it had completed its annual compliance when the federal Form 990 went out in May. Six months later, the executive director discovered that the CHAR500 had never been filed — the previous controller had assumed the 990 satisfied state requirements. The Charities Bureau had already flagged the organization as delinquent, and a major foundation pulled an in-progress grant application after a routine due diligence search returned the delinquency notice. The organization spent four weeks remediating the filing and another two months explaining the lapse to funders. Nothing about the underlying program was wrong. The compliance gap was administrative.
New York’s compliance landscape is unusually layered. The state requires CHAR500 registration with the Attorney General under either Article 7-A (solicitation) or EPTL (charitable trusts), and most New York-active nonprofits are registered under both. The NYC Department of Consumer and Worker Protection regulates in-person charitable solicitation within the five boroughs. The NYC Department of Health and Mental Hygiene issues activity-specific permits for any nonprofit running food, childcare, or residential programs. And city contract holders carry their own VENDEX and MWBE reporting on top of all of that.
The 12 questions below address the cross-cutting state and city filings, the audit thresholds that trip up mid-sized nonprofits, and the specific points where state and city compliance interact. For a deeper view of New York grant funding sources, see the NYC community foundation grants guide. For the federal layer that sits on top, 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 110,000 active 501(c)(3) public charities are registered with the IRS in New York State as of recent BMF extracts.
Roughly 40,000 nonprofits operate within the five boroughs of New York City, the largest concentration in any single U.S. city.
Source: IRS BMF (geographic extract) and NYC Mayor's Office of Nonprofit Services
CHAR500 audit threshold has been set at $1,000,000 in gross revenue and support since the most recent revision under the Non-Profit Revitalization Act.
Annual financial report filed by registered charities with the New York State Attorney General's Charities Bureau.
DEFINITION
Article 7-A
Section of the New York Executive Law governing charitable solicitation registration.
DEFINITION
EPTL
Estates, Powers and Trusts Law — governs registration of organizations holding charitable assets in trust in New York.
DEFINITION
DCWP
New York City Department of Consumer and Worker Protection, which licenses certain in-person charitable solicitation in NYC.
DEFINITION
DOHMH
New York City Department of Health and Mental Hygiene, which issues activity-based permits for nonprofits operating food, childcare, residential, and similar regulated programs.
Q&A
Do New York City nonprofits register at both the state and city level?
Most NYC nonprofits register with the Charities Bureau (state) for charitable solicitation and with DCWP (city) only if they conduct in-person solicitation in the five boroughs. Activity-based DOHMH permits apply on top of charitable registration when the nonprofit operates regulated programs.
Q&A
Can a nonprofit incorporated in another state operate in NYC without re-incorporating?
Yes. A foreign nonprofit corporation can register to do business in New York via the Department of State (Application for Authority) and register to solicit under Article 7-A — re-incorporation is not required. Most national nonprofits operate this way.
Q&A
What are the most common CHAR500 errors?
Mismatches between CHAR500 and Form 990 totals; missed audit thresholds where a CPA review was filed when an audit was required; incomplete CT-12 schedules for organizations using professional fundraisers; and missed extension deadlines.
Frequently asked
Frequently Asked Questions
What is the CHAR500 and who has to file it?
The CHAR500 is the annual financial report filed with the New York State Attorney General's Charities Bureau by every charitable organization registered to solicit funds in New York. Organizations registered under Article 7-A of the Executive Law (charitable solicitation) must file regardless of whether any New York funds were solicited that year. The form bundles the financial disclosures with the schedule of executive compensation and, for organizations above thresholds, an independent CPA review or audit. File electronically at ag.ny.gov/charities.
When is CHAR500 due and what extension is available?
CHAR500 is due 4.5 months after fiscal year end — the same cadence as the federal Form 990. For a calendar year nonprofit, that is May 15. New York grants an automatic 180-day extension on request via the Charities Bureau portal; you must file the extension request before the original due date. Organizations that file Form 990 with a federal extension should still file the New York extension separately — the federal extension does not cover the state.
When does my CHAR500 require an audited financial statement?
Audit thresholds are set by the New York Non-Profit Revitalization Act and are tied to gross revenue and support: organizations with gross revenue and support over $1,000,000 must submit an independent CPA audit; organizations between $250,000 and $1,000,000 must submit a CPA review (not audit); organizations under $250,000 may file without either. These thresholds reset on July 1 periodically and have moved up over the past decade — confirm the current threshold on the Charities Bureau site before contracting an auditor for compliance reasons alone.
What is the difference between Article 7-A registration and EPTL registration?
New York maintains two registration tracks. Article 7-A registration applies to organizations that solicit charitable contributions in New York, regardless of where the organization is incorporated. EPTL registration (Estates, Powers and Trusts Law Article 8) applies to organizations holding assets in trust for charitable purposes in New York. Many nonprofits are dual-registered — incorporated under EPTL and soliciting contributions under Article 7-A. The CHAR500 covers both tracks, but the registration triggers and exemptions are different. New York-incorporated 501(c)(3)s with assets are EPTL-registered automatically; out-of-state organizations soliciting in New York must register under Article 7-A before any solicitation.
When do I need a NYC DCWP charitable solicitation license?
The NYC Department of Consumer and Worker Protection (formerly DCA) regulates door-to-door, street, and certain other in-person charitable solicitation within the five boroughs. If your organization conducts door-to-door fundraising, street canvassing, or certain in-person solicitation events in NYC, you must obtain a DCWP license in addition to your state Article 7-A registration. Mail and online solicitation generally do not trigger DCWP licensing, but check the current rules at nyc.gov/site/dca — definitions have expanded periodically.
Does my nonprofit need a NYC DOHMH permit?
DOHMH permits are activity-driven, not entity-driven. Nonprofits running food programs (food pantries, soup kitchens, congregate meals) need DOHMH food service permits for the locations where food is prepared or served. Nonprofits operating childcare or after-school programs need separate childcare permits. Nonprofits running residential or shelter programs need permits specific to those uses. Confirm at nyc.gov/site/doh which permits apply before launching a new program — operating without the correct permit is a violation that compounds quickly through the city's enforcement system.
What is the NY-CT-12 form?
The CT-12 (and CT-12F) is a schedule that accompanies the CHAR500 for organizations registered under Article 7-A. It collects detail on professional fundraisers and fundraising counsel engaged during the year, plus the gross receipts and percentage retained by the organization for each campaign. If you contracted a fundraising firm, that firm must also be separately registered with the Charities Bureau and provide its own contract filings. Mismatches between the nonprofit's CT-12 and the fundraiser's filings are a common audit trigger.
How does NYC-incorporated status interact with NYC contracting requirements?
Many NYC nonprofits hold contracts with city agencies through HHS Accelerator or similar procurement portals. These contracts impose their own compliance regime — VENDEX disclosures, MWBE reporting, prevailing wage requirements for construction-related contracts, and contract-specific reporting that runs separately from CHAR500 and IRS Form 990. A clean state and federal compliance posture does not satisfy NYC contracting requirements, and a city contracting issue can flow back to the state — the Charities Bureau receives referrals from city agencies for nonprofits with significant contracting concerns.
What annual filings do I need with the New York Department of State?
Most New York nonprofits do not file an annual report with the Department of State (this is different from many other states). However, you must keep your registered agent and address current with the Department of State, and any name changes, mergers, or dissolutions require filings under the Not-for-Profit Corporation Law. The annual financial filing is the CHAR500, made to the Attorney General — not to the Department of State.
What happens if my CHAR500 is late?
Late filing of the CHAR500 results in delinquency status with the Charities Bureau, which is publicly visible on the Charities Bureau search and flagged in the Federal Audit Clearinghouse cross-check for organizations subject to single audit. Continued non-filing can result in civil penalties, suspension of registration, and ultimately, loss of charitable solicitation authority in New York. Most foundations doing due diligence in New York pull the Charities Bureau record — a delinquency flag will surface in grant decisions before you know it has been pulled.
Do I need to file a CHAR500 if I had no New York revenue this year?
Yes. Once registered under Article 7-A, an organization must file CHAR500 annually until it formally withdraws registration, regardless of whether any New York-source revenue was received. Organizations that pause New York solicitation but expect to resume should continue filing rather than withdrawing — re-registering is a more involved process than maintaining an active registration. To withdraw, file a CHAR500 indicating final filing and submit a withdrawal letter to the Charities Bureau.
How do CHAR500 and the federal Form 990 interact?
CHAR500 incorporates the federal Form 990 by reference — most organizations attach a copy of their 990 to the CHAR500 filing. Discrepancies between the two filings are a common audit trigger. Any restatement of the 990 (amended 990) requires a corresponding amended CHAR500. Plan the filings together: complete the 990 first, then build the CHAR500 from the same numbers, and have one person reconcile the two before submission.
