Virginia Charitable Registration: Nonprofit Filing Guide

Virginia’s 90-day renewal window is the defining operational challenge of this filing. Most states give nonprofits 4.5 to 10 months after fiscal year end to complete their charitable registration renewal. Virginia gives 90 days. For organizations requiring audited or reviewed financial statements, that window requires advance planning — the CPA engagement must begin before or immediately at fiscal year close.

What Virginia requires and why it differs

Virginia’s Charitable Solicitation Law (Va. Code Ann. § 57-48 et seq.) requires charitable organizations to register with the Office of Charitable and Regulatory Programs before soliciting contributions from Virginia residents. OCRP is part of the Department of Social Services — an administrative placement that differs from the Attorney General oversight model used by most states.

The 90-day renewal window, the reviewed-statement requirement at $750,000, and the audited-statement requirement at $1 million create a financial reporting calendar that must be planned before fiscal year close, not after.

Who must register

Any organization that solicits contributions from Virginia residents — regardless of where the organization is incorporated or headquartered — must register before soliciting. Solicitation includes:

• Direct mail campaigns to Virginia residents
• Online campaigns accessible to Virginia donors
• Telephone solicitation
• In-person fundraising events held in Virginia

Virginia follows the Charleston Principles on online solicitation: organizations that specifically target Virginia residents online are soliciting in Virginia.

Exemptions from registration

Virginia Code § 57-60 exempts:

The small-organization exemption requires both conditions concurrently. Once an organization exceeds $5,000 in contributions or engages a paid solicitor, registration is required before the next solicitation.

Renewal deadline: 90 days after fiscal year end

This is among the shortest renewal windows in the country. By comparison, New York’s CHAR500 allows 4.5 months; California’s RRF-1 allows 4 months 15 days; Connecticut’s DCP renewal allows 10 months.

Fee schedule

Financial statement requirements

Virginia’s financial statement tiers are more granular than most states:

The $750,000 reviewed-statement threshold means organizations below the $1 million audit level still need CPA involvement. A CPA compilation (the lowest level of CPA involvement) is sufficient between $200,000 and $749,999. This is distinct from the federal Single Audit threshold, which is based on federal expenditures, not gross revenue.

Virginia vs. federal audit thresholds: what each covers

An organization with $900,000 in gross revenue and $800,000 in federal expenditures clears the federal Single Audit threshold but not Virginia’s audit threshold — it needs a CPA review for Virginia and a Single Audit for federal purposes. The same CPA firm often handles both engagements in a coordinated schedule.

Professional fundraiser and fundraising counsel disclosure

Virginia requires registration and disclosure for:

• Professional solicitors — paid to directly solicit contributions. Must register with OCRP before any campaign.
• Fundraising counsel — advises on strategy without directly soliciting. Must also register.
• Commercial co-venturers — businesses that donate a portion of product sales to the organization. Separate disclosure requirements apply.

All contracts with professional solicitors and fundraising counsel must be filed with OCRP before the campaign begins and disclosed in the annual renewal.

Required attachments checklist

• Completed OCRP renewal application
• Form 990, 990-EZ, or 990-PF (complete with all schedules)
• Financial statements at applicable tier (internal, compiled, reviewed, or audited)
• Current list of officers and directors
• Disclosure of all professional solicitors and fundraising counsel engaged during the period
• Correct fee payment

Common rejection reasons

OCRP deficiency notices most commonly cite:

1. Missing Form 990 — required regardless of 990-N e-Postcard status
2. Wrong financial statement tier — particularly organizations that cross $750,000 and submit only an internal statement
3. Late filing — the 90-day deadline is firm; late filings accrue penalties
4. Missing fundraiser disclosures — failure to list professional solicitors and fundraising counsel
5. Missing officer list — must be current as of the fiscal year end being reported

How GrantPipe helps

GrantPipe tracks Virginia’s 90-day renewal deadline from the organization’s fiscal year end and flags the required financial statement tier based on gross revenue. For organizations managing Virginia OCRP alongside federal grant reporting, Single Audit coordination, and multi-state charitable registration, the compliance calendar keeps every deadline and documentation requirement in one operating record. Start with a free trial to set up the Virginia compliance timeline before the 90-day clock starts.

DEFINITION

OCRP

Virginia's Office of Charitable and Regulatory Programs, a division of the Department of Social Services. Administers charitable solicitation registration and oversight in Virginia under Va. Code Ann. § 57-48 et seq.

DEFINITION

Gross revenue

Total income from all sources during the fiscal year, used to determine Virginia's registration fee tier and financial statement requirement. Government grants and program service revenue are included unless specifically excluded by the organization's accounting methodology.

DEFINITION

Fundraising counsel

A person or entity that advises a charitable organization on fundraising strategy and practices but does not directly solicit contributions. Must register separately with OCRP and be disclosed in the organization's annual renewal.

DEFINITION

Professional solicitor

A person or entity that directly solicits contributions on behalf of a charitable organization, typically for compensation. Must register separately with OCRP before conducting any campaign.

DEFINITION

CPA-compiled financial statement

Financial statements prepared by a CPA without independent verification procedures. Acceptable for Virginia charitable registration when gross revenue is between $200,000 and $749,999.