TLDR
Ohio requires charitable organizations soliciting in the state to register with the Ohio Attorney General's Charitable Law Section and file an annual financial report using Form CFR-1. The annual report is due within 120 days of the fiscal year end — which is May 15 for calendar-year filers, earlier than many organizations expect. Fees range from $0 to $200. Ohio's audit threshold is $500,000 in gross revenue. A separate Ohio corporate annual report is due with the Secretary of State.
Ohio Charitable Registration: Nonprofit Filing Guide
Ohio’s charitable registration framework is administered by the Attorney General’s Charitable Law Section — a distinction from states that route oversight through the Secretary of State or a consumer protection agency. This matters operationally because the Ohio AG actively investigates charitable fraud and misuse, and delinquent registrations receive closer scrutiny than in states where the registration office is purely administrative.
The 120-day annual report deadline is the key planning driver. Calendar-year filers have until May 15. That window — identical to California’s RRF-1 deadline — lands before most other states’ deadlines, which means Ohio’s CFR-1 should anchor the multi-state compliance calendar.
What Ohio’s charitable registration covers
Ohio Revised Code Chapter 1716 requires organizations that solicit contributions from Ohio residents to register with the Attorney General’s Charitable Law Section. The requirement covers:
- Charitable organizations incorporated in Ohio
- Out-of-state organizations soliciting Ohio residents
- Charitable trusts with Ohio assets
- Professional solicitors and fundraising counsel operating in Ohio
The registration requirement applies before the first solicitation. Organizations that begin soliciting while awaiting registration approval face potential enforcement action.
Who is exempt
Ohio Revised Code § 1716.02 exempts:
| Category | Conditions |
|---|---|
| Religious organizations | All conditions per statute |
| Educational institutions | Soliciting among students, faculty, alumni, or patrons |
| Hospitals | Licensed in Ohio |
| Volunteer fire departments | Soliciting in service territory |
| Political organizations | Registered with election authorities |
| Veterans organizations | Soliciting among members |
| Small organizations | Contributions of $25,000 or less AND no paid solicitors |
The small-organization exemption — $25,000 and no paid solicitors — is lower than most states’ thresholds. Ohio organizations that hire any paid solicitor or fundraising staff lose the exemption regardless of contribution level.
Annual report deadline: 120 days after fiscal year end
| Fiscal Year End | CFR-1 Due |
|---|---|
| December 31 | May 15 |
| March 31 | July 29 |
| June 30 | October 28 |
| September 30 | January 28 |
The 120-day window is firm. Ohio does not provide automatic extensions comparable to the IRS Form 990 extension process. Organizations should contact the Charitable Law Section if unusual circumstances prevent timely filing.
Fee schedule
Annual report fees are based on total contributions received:
| Contributions Received | Annual Report Fee |
|---|---|
| $10,000 or less | $0 |
| $10,001 – $50,000 | $50 |
| $50,001 – $100,000 | $100 |
| $100,001 – $500,000 | $150 |
| Over $500,000 | $200 |
Note: The initial registration fee is $200, paid once at the time of first registration. Annual report fees apply to every subsequent filing.
Audit requirement
Ohio requires audited financial statements when gross revenue exceeds $500,000. This is a revenue-based threshold, distinct from:
- The federal Single Audit threshold: $1,000,000 in federal expenditures (raised from $750,000 for fiscal years ending September 30, 2025 or later)
- California’s threshold: $2,000,000 in gross annual revenue
- New Jersey’s threshold: $500,000 in gross revenue (same as Ohio)
- Connecticut’s threshold: $500,000 in gross revenue (same as Ohio)
- Pennsylvania’s threshold: $300,000 in gross revenue (lower than Ohio)
Organizations managing multi-state registrations often find that Pennsylvania’s $300,000 threshold drives the CPA audit engagement. Once a full audit exists, it satisfies Ohio’s $500,000 requirement without additional work.
Separate Ohio Secretary of State annual report
Ohio nonprofit corporations must also file an annual report with the Ohio Secretary of State by the last day of the anniversary month of incorporation. The fee is $25. This maintains corporate existence and is entirely separate from the charitable registration renewal. A lapsed Secretary of State annual report can result in administrative dissolution even if the Attorney General registration is current.
Professional solicitor requirements
Professional solicitors and fundraising counsel operating in Ohio must register independently with the Charitable Law Section before conducting any campaign. Charitable organizations must:
- Verify that any professional solicitor they engage is registered in Ohio
- File a copy of the solicitor contract with the Charitable Law Section before the campaign begins
- Disclose all professional solicitors in the CFR-1 annual report
Failure to disclose solicitors or to verify their Ohio registration can result in deficiency notices and potential enforcement action against the charitable organization.
Required attachments for CFR-1
- Completed Form CFR-1 with authorized officer signature
- Complete copy of Form 990, 990-EZ, or 990-PF
- Audited financial statements (gross revenue over $500,000)
- Internal financial statements (gross revenue $500,000 or less)
- Professional solicitor disclosures and contract copies
Common rejection reasons
The Charitable Law Section most often issues deficiency notices for:
- Missing Form 990 — required regardless of 990-N status
- Fee miscalculation — using total revenue instead of contributions received
- Missing audit — organizations over $500,000 that submit only an internal financial statement
- Late filing — Ohio’s 120-day window is stricter than most; late fees and penalties apply
- Missing solicitor disclosures — professional solicitor contracts omitted from the filing
Multi-state context
Ohio’s CFR-1 deadline at May 15 for calendar-year filers is one of the earliest in the Midwest. Illinois’s AG990-IL is due 6 months after fiscal year end; Michigan’s deadline is 7 months. Ohio-based organizations soliciting across Midwestern states should build their compliance calendar around the Ohio May 15 deadline as the anchor.
How GrantPipe helps
GrantPipe tracks Ohio’s 120-day CFR-1 deadline alongside Michigan, Illinois, and other Midwestern state filings, federal grant reporting deadlines, and restricted-fund workflow in one compliance record. The system auto-calculates the May 15 deadline from the organization’s fiscal year end, flags the audit requirement at $500,000 gross revenue, and ensures no Ohio deadline gets buried behind other obligations. Start with a free trial to build a compliance calendar that puts Ohio’s early deadline front and center.
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- CFR-1
- Ohio's Annual Financial Report form for registered charitable organizations. Filed with the Ohio Attorney General's Charitable Law Section within 120 days of fiscal year end.
DEFINITION
- Charitable Law Section
- The division of the Ohio Attorney General's office responsible for registering and regulating charitable organizations and professional solicitors under Ohio Revised Code Chapter 1716.
DEFINITION
- Gross revenue
- Total income from all sources for the fiscal year, used to determine Ohio's annual report fee tier and the audit requirement. Form 990 Part I Line 12 is typically used for this calculation.
DEFINITION
- Professional solicitor
- A person or entity paid to solicit contributions on behalf of a charitable organization. Must register separately with the Ohio Attorney General's Charitable Law Section before conducting any solicitation.
DEFINITION
- Ohio Revised Code Chapter 1716
- The Ohio statute governing charitable organizations, charitable trusts, professional solicitors, and fundraising counsel. Sets registration, reporting, and fee requirements.
DEFINITION
Q&A
Why is Ohio's CFR-1 deadline earlier than most states?
Ohio's 120-day post-fiscal-year deadline is set by statute under ORC Chapter 1716. Most states use windows of 135 to 185 days; Ohio's 120-day window places calendar-year filers at May 15 — the same as California's RRF-1. For organizations managing multiple state registrations, the Ohio deadline often arrives before other states' deadlines and should be calendared accordingly.
Q&A
Does Ohio's charitable registration audit threshold differ from the federal Single Audit threshold?
Yes. Ohio's threshold is $500,000 in gross revenue. The federal Single Audit threshold is $1,000,000 in federal expenditures under the 2024 Uniform Guidance revision (raised from $750,000). These are independent requirements with different bases — revenue vs. expenditures. An organization with $600,000 in gross revenue and $600,000 in federal expenditures needs an Ohio audit and is below the federal Single Audit threshold. Same CPA engagement can often be structured to cover both.
Q&A
What happens if Ohio charitable registration lapses?
A lapsed registration prohibits solicitation in Ohio. The Attorney General's Charitable Law Section can issue cease-and-desist orders and civil penalties for solicitation during a lapsed period. Reinstatement requires filing all overdue CFR-1 reports, paying all overdue fees, and resolving any outstanding deficiencies. The reinstatement process can take several weeks.
Frequently asked