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Florida Nonprofit Compliance FAQ: CH-14 Charitable Solicitation, FDACS Renewal, and Audit Thresholds

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TLDR

Any charity that solicits contributions from Florida residents — regardless of where the charity is incorporated — must register with the Florida Department of Agriculture and Consumer Services (FDACS) under Chapter 496 of the Florida Statutes before soliciting and renew annually on the anniversary of registration. Organizations with $1 million or more in annual contributions must include audited financial statements; $500,000 to $1 million requires a CPA review. Soliciting without registration is a third-degree felony under Florida Statute 496.419, and FDACS pursues unregistered solicitors actively.

A mid-sized Florida nonprofit added an online giving campaign in October ahead of giving season. Its CH-14 had been renewed twice on time, anchored to the May registration anniversary. In November, FDACS issued a citation: the email solicitations omitted the required 1-800-HELP-FLA disclosure language in their footer. The campaign had to be paused, the email service provider templates updated, and a corrective response filed — all in the middle of the year-end appeal window.

Florida enforces charitable solicitation rules more aggressively than most states. The Department of Agriculture and Consumer Services maintains a public registration database, criminalizes unregistered solicitation as a third-degree felony, and treats the disclosure language as a hard requirement. These 13 questions cover what every Executive Director and Finance Manager operating in Florida needs to know.

Registration is required before solicitation, not after

The most common Florida compliance error is treating CH-14 as a post-launch task. Florida Statute 496.405 is unambiguous: registration is required before any solicitation in Florida. The clock starts when the first solicitation goes out — direct mail drop, email send, social ad campaign, donate page promotion — not when the first dollar arrives.

CH-14 renewal anchors to anniversary, not fiscal year

Florida is one of the few states where annual renewal calendars off the original registration date rather than fiscal year end. If you registered on June 12, your renewal is due every June 12 — independent of when your fiscal year closes. This single fact accounts for most late filings among multi-state organizations that calendar by habit.

The $1 million audit threshold is contribution-based

Florida’s audit threshold applies to annual contributions, not gross revenue. Earned revenue, government grants, and investment income generally do not count. An organization with $2 million in gross revenue but only $400,000 in contributions stays below the audit threshold. An organization with $1.1 million in contributions and minimal other revenue crosses it.

CPA review at $500,000 is a separate tier

Below $1 million but above $500,000 in contributions, a CPA review report is required. Reviews are less expensive than audits — typically $5,000 to $12,000 versus $15,000 to $40,000 for an audit — but require an engaged CPA firm. Most nonprofits scheduling at this tier book by November of the prior year.

Required disclosure is mandatory on every solicitation

Florida Statute 496.411 requires the full disclosure statement on every solicitation that asks for money. Email footers, donate pages, direct mail, event programs, and broadcast appeals must all include it. Truncated or missing disclosures generate FDACS citations independent of registration status.

Florida is the third-largest nonprofit sector

Florida hosts approximately 95,000 registered 501(c)(3) public charities — the third-largest sector after California and New York. The volume of registered charities means FDACS has practical enforcement experience and processes filings on a predictable cadence.

Pass-through funding from Florida agencies carries federal compliance

The Department of Children and Families, Department of Commerce (formerly DEO), and Department of Health route significant federal HHS, HUD, and DOJ dollars through nonprofit subrecipients. Those funds carry 2 CFR 200 — the federal Uniform Guidance — including restricted fund accounting, allowable cost documentation, and Single Audit exposure at $1,000,000 in federal expenditures for fiscal years ending September 30, 2025 or later.

Sunbiz annual report is separate from CH-14

Florida-formed nonprofits file a corporate annual report with the Department of State (Sunbiz) by May 1 each year. The fee is $61.25. This filing is independent of the CH-14 charitable registration — missing one does not affect the other, but missing both is two separate compliance failures with separate penalties.

Practical sequence for new Florida nonprofits

File the corporate Articles of Incorporation with Sunbiz under Chapter 617. Obtain the EIN. Adopt bylaws and appoint directors. File CH-14 with FDACS before any solicitation activity, attaching the IRS Form 1023 if pending. Once the IRS determination letter arrives, update the FDACS file. Calendar the CH-14 renewal anniversary precisely. Calendar the May 1 Sunbiz report. If approaching $1 million in annual contributions, engage an audit firm by November.

Online platforms and Florida-targeted appeals

Donor management platforms and email service providers default to including all subscribers in solicitation campaigns unless explicitly segmented. A national email list will include Florida residents, and an unregistered organization soliciting that list is in violation. Either register with FDACS or segment Florida residents out of solicitation campaigns until registration is active.

Suspension and reinstatement

Continued non-filing of CH-14 leads to suspension. A suspended organization loses the right to solicit in Florida and may be referred for criminal enforcement. Reinstatement requires filing all delinquent renewals, paying accumulated late fees, and submitting a written explanation. FDACS can deny reinstatement for repeat or willful violations.

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Florida CH-14 fees range from $10 (under $5,000 contributions) to $400 (over $10 million), based on prior-year total contributions.

Source: Florida Department of Agriculture and Consumer Services — Solicitation of Contributions

Audited financial statements are required at $1 million or more in annual contributions; CPA review at $500,000 to $1 million.

Source: Florida Statutes Chapter 496

Soliciting without registration is a third-degree felony under Florida Statute 496.419 with civil fines up to $5,000 per violation.

Source: Florida Department of Agriculture and Consumer Services — Enforcement

DEFINITION

FDACS
Florida Department of Agriculture and Consumer Services. Through its Division of Consumer Services, FDACS administers the Solicitation of Contributions Act under Chapter 496 of the Florida Statutes.

DEFINITION

CH-14
Charitable Organizations and Sponsors Registration Application. The form filed with FDACS to register or renew under Chapter 496.

DEFINITION

Solicitation of Contributions Act
Chapter 496, Florida Statutes. Governs charitable solicitation registration, disclosure, and enforcement in Florida, including criminal penalties for unregistered solicitation.

DEFINITION

Required disclosure
The mandatory FDACS registration disclosure (1-800-HELP-FLA citation and 'registration does not imply endorsement' statement) that must appear on every Florida solicitation.
“Florida is one of the few states where renewal date anchors to your original registration anniversary. Half the late filings I see come from organizations that calendared off fiscal year close out of habit.”

Compliance practitioner , Charitable registration consultant at Multi-state practice
“FDACS treats the disclosure language as a hard requirement. The full statement must appear on every solicitation that asks for money, including emails and social posts. Truncated disclosures get cited.”

Compliance specialist , Nonprofit attorney at Florida-licensed practice

Frequently asked

Frequently Asked Questions

Do I need to register with Florida to solicit donations?
Yes, if you solicit contributions from Florida residents. Under Florida Statute 496.405, every charitable organization, sponsor, professional fundraising consultant, and professional solicitor must register with the Florida Department of Agriculture and Consumer Services (FDACS) before soliciting in Florida. Registration is required regardless of the state where you are incorporated. An out-of-state nonprofit that solicits Florida donors through email, social media, direct mail, or a targeted donate page is required to register.
Which form do I file to register initially in Florida?
Form CH-14 (Charitable Organizations and Sponsors Registration Application) filed with FDACS, Division of Consumer Services. The fee scales with prior fiscal year contributions: $10 (under $5,000), $75 ($5,000 to $99,999.99), $125 ($100,000 to $199,999.99), $200 ($200,000 to $499,999.99), $300 ($500,000 to $9,999,999.99), and $400 ($10 million or more). File via the online portal at FDACS.gov/Business-Services/Solicitation-of-Contributions.
When is CH-14 renewal due?
Annually on the anniversary of your initial registration, not aligned to fiscal year end. This is unusual nationally — most state filings calendar off May 15 or another fiscal-year-aligned date. Florida anchors renewal to the original registration date. Calendar this precisely; late renewals incur a $25 per month delinquency fee.
What is Florida's audit threshold?
Florida requires audited financial statements prepared by an independent CPA when annual contributions equal or exceed $1,000,000. Contributions between $500,000 and $1,000,000 require a CPA review report (SSARS standard). Below $500,000, internal financial statements signed by an officer are acceptable. The threshold applies to contributions, not gross revenue — earned revenue and government grants are generally excluded.
What is the required disclosure language?
Florida Statute 496.411 requires every solicitation to include the registration number (SC-#######) and the statement: 'A COPY OF THE OFFICIAL REGISTRATION AND FINANCIAL INFORMATION MAY BE OBTAINED FROM THE DIVISION OF CONSUMER SERVICES BY CALLING TOLL-FREE 1-800-HELP-FLA (435-7352) WITHIN THE STATE OR BY VISITING WWW.FDACS.GOV. REGISTRATION DOES NOT IMPLY ENDORSEMENT, APPROVAL, OR RECOMMENDATION BY THE STATE.' This language is mandatory on direct mail, email, donate pages, event programs, and broadcast appeals.
What happens if I solicit without registering?
Soliciting without an active registration is a third-degree felony under Florida Statute 496.419, punishable by up to five years in prison plus civil fines of up to $5,000 per violation. FDACS pursues unregistered solicitors actively, particularly during disaster response periods and high-profile fundraising events. The Division of Consumer Services publishes enforcement actions on its public website.
Are there exemptions from Florida charitable registration?
Limited exemptions under Florida Statute 496.404 include religious institutions, accredited educational institutions soliciting from constituencies, political committees, and small organizations with under $25,000 in annual contributions that compensate no person for solicitation. The exemption is narrow. Most public charities do not qualify and must register. FDACS verifies exemption claims and rejects overbroad assertions.
Do online donations from Florida residents trigger registration?
Yes when solicitation is directed at Florida residents — including targeted email, social media advertising, donor list segmentation, or a donate page promoted to Florida audiences. A passive online giving page that incidentally receives a Florida gift is a closer call, but FDACS's enforcement posture is conservative. If you know donations are coming from Florida, register.
Do I register with FDACS before or after IRS 501(c)(3) determination?
Either. Florida allows initial registration with a pending Form 1023 attached. Once the IRS determination letter is issued, submit a copy to update the FDACS file. Many new organizations register with FDACS before federal determination because the trigger is solicitation, not federal recognition.
How long does Florida CH-14 registration take?
FDACS processes complete CH-14 filings in 10 to 20 business days. Common rejections — missing IRS letter, financial statements at the wrong tier, incomplete officer list — extend the timeline. Submit a complete package the first time.
Do Florida professional fundraisers have separate registration?
Yes. Professional fundraising consultants and professional solicitors register separately with FDACS under Chapter 496. Solicitor registration includes bonding requirements ($50,000 surety bond) and contracts with charities must be filed with FDACS before solicitation begins. Charities that engage paid solicitors must verify the solicitor's active registration.
What records do Florida nonprofits have to keep?
Florida Statute 496.4101 requires charities to maintain records sufficient to verify all CH-14 reporting for at least three years. Standard practice extends this: financial records seven years minimum, board minutes permanently, and donor restriction documentation for the life of the restriction plus seven years after release. FDACS can audit and request supporting documentation for any line item.
Does Florida require a separate state corporate filing?
Yes. Florida nonprofits incorporate with the Florida Department of State, Division of Corporations (Sunbiz) under Chapter 617, the Florida Not-for-Profit Corporation Act. Annual reports are due by May 1 each year with a $61.25 fee. The corporate filing is separate from CH-14 charitable registration — both are required for Florida-formed nonprofits.