TLDR
Every Illinois charitable organization soliciting contributions in Illinois must register with the Illinois Attorney General Charitable Trust Bureau before solicitation begins. Form CO-1 is the initial registration ($15); Form AG990-IL is the annual renewal due six months after fiscal year end — unusual nationally, where most state filings calendar off four-and-a-half months. Audit thresholds are low: contributions of $300,000 or more require audited financial statements; contributions of $25,000 to $300,000 require CPA-reviewed statements. The Charitable Trust Bureau actively monitors registered charities and posts delinquency lists that funders check.
What This Workflow Covers
The Illinois Attorney General Charitable Trust Bureau administers charitable registration under the Charitable Trust Act (760 ILCS 55) and the Solicitation for Charity Act (225 ILCS 460). This workflow walks through CO-1 initial registration and the recurring AG990-IL, including the unusual six-month-after-fiscal-year-end deadline and the $300,000 audit threshold.
For broader Illinois formation context, see the Illinois nonprofit startup guide. For software that wires AG990-IL into a deadline calendar alongside grant reports, see the Illinois grant management software buyer’s guide.
Step 1: Confirm the Registration Trigger
Time: 1 day
Illinois requires registration before any solicitation in Illinois. The trigger is solicitation activity, not residency or asset receipt. Common scenarios that require registration:
- A donate page accessible to Illinois residents and promoted through email or social ads
- Direct mail appeals targeting Illinois ZIP codes
- Capital campaigns engaging Illinois-based major donors
- Grant applications to Illinois-based foundations
- Peer-to-peer fundraising involving Illinois participants
Out-of-state nonprofits soliciting Illinois donors must register on the same terms. Geography is determined by where the donors are.
Limited exemptions under 760 ILCS 55/3 cover certain religious organizations, accredited educational institutions, and a few narrow categories. Most public charities do not qualify and must register. The Charitable Trust Bureau verifies exemption claims.
Step 2: Assemble the CO-1 Attachments
Time: 2–5 days
Before filing, gather:
- Form CO-1 — current version downloaded from the Illinois AG website
- Articles of Incorporation — file-stamped copy from Illinois Secretary of State (or home state for out-of-state)
- Bylaws — adopted by the board, signed and dated
- IRS Form 1023 — the application as filed, including all schedules. If the IRS determination letter is already issued, attach that too.
- List of officers and directors — names, titles, and addresses
- Most recent financial statements — or budget if newly formed
- $15 filing fee — check payable to “Illinois Charity Bureau Fund”
Submit by mail to the Charitable Trust Bureau in Chicago, or through the AG’s portal where available.
Step 3: File CO-1 and Capture the Registration Number
Time: 30–60 days for AG processing
The AG returns a CO-####### registration number once the filing is accepted. This number is your organization’s permanent reference for all future filings and appears on solicitation disclosures, AG990-IL forms, and grant applications from Illinois foundations.
Store the CO number in your compliance records, your CRM or grant management system, and your finance team’s accounting platform.
While waiting, you may begin operations and solicitation in Illinois — but the CO-1 must be filed before solicitation begins, not after.
Step 4: Build the Annual AG990-IL Calendar
Time: 1 hour, but governs every future year
The AG990-IL is due 6 months after fiscal year end:
- Calendar-year filers (Jan 1 – Dec 31): due June 30
- July 1 – June 30 fiscal year: due December 31
- October 1 – September 30 fiscal year: due March 31
This is the most common scheduling error among multi-state organizations. Most state filings — including federal Form 990 — calendar off 4.5 months after fiscal year end. Illinois adds 6 weeks. Calendar this precisely.
Build a compliance calendar with three reminders:
- 120 days out — confirm Form 990 will be ready
- 90 days out — confirm audit or review is on track if applicable
- 30 days out — assemble AG990-IL package and confirm fee tier
The renewal fee scales based on prior-year contributions:
- Under $15,000: $15
- $15,000 to $100,000: $50
- $100,000 to $1 million: $100
- Over $1 million: $200
Step 5: Prepare Audit or Review Attachments
Time: 8–12 weeks for audit; 4–6 weeks for review
Illinois’s financial statement thresholds are among the lower nationally:
- $300,000 or more in contributions: audited financial statements by an independent CPA, prepared in accordance with Generally Accepted Auditing Standards
- $25,000 to $300,000 in contributions: CPA-reviewed financial statements (SSARS standard)
- Under $25,000 in contributions: internal financial statements signed by an officer
Auditors and CPAs serving the nonprofit sector are at capacity January through April. For a calendar-year filer with a June 30 AG990-IL deadline, schedule the audit engagement by November of the prior year. Audit fieldwork typically begins in February or March; the report is delivered May to early June.
Step 6: File AG990-IL with Attachments
Time: 4–8 hours assembling, 30 minutes filing
The AG990-IL itself is a 4-page form. The work is in assembling supporting documents:
- Most recent IRS Form 990, 990-EZ, or 990-PF (or 990-N e-Postcard for smallest orgs)
- Audited financial statements if contributions ≥ $300,000
- Reviewed financial statements if contributions $25,000–$300,000
- Filing fee based on contributions tier
- Schedule B redactions — donor names should be redacted from public copies
Submit by mail to the Charitable Trust Bureau or through the AG’s portal. The Charitable Trust Bureau does not always send receipt confirmations automatically — request confirmation if not received within 30 days.
Step 7: Track Delinquency and Reinstatement Risk
The Illinois AG publishes a delinquency list of organizations with overdue filings. Funders check it. Once an organization appears, Illinois community foundations and many private foundations pause grant payments until the registry status is restored.
Reinstatement workflow:
- File all past-due AG990-IL forms (one per missed year)
- Pay all past fees plus penalties
- Wait for AG processing — typically 60 to 90 days
- Confirm removal from delinquency list before resuming Illinois fundraising
The penalty cost is small relative to the reputational cost with funders. Treat the June 30 (or fiscal-year-equivalent) deadline as immovable.
Common Edge Cases
Fiscal year change. If the board changes the fiscal year, file a short-period AG990-IL covering the stub period. The AG adjusts the renewal calendar going forward.
Mergers and dissolutions. Both require notice to the AG via dissolution forms before completion. Funds remaining at dissolution must be distributed to another 501(c)(3), per the Articles of Incorporation dissolution clause.
Out-of-state nonprofits soliciting in Illinois. Foreign corporations soliciting Illinois donors must file CO-1 with the Illinois AG. No separate Illinois corporate filing is required for charitable registration alone — that is a separate Secretary of State matter for transacting business.
Commercial fundraisers and counsel. Separate registration applies under 225 ILCS 460/2 — different forms and bonding requirements at the AG’s office. Charities engaging commercial fundraisers must verify the fundraiser’s active registration.
Religious organization exemption. Some religious organizations are exempt under 760 ILCS 55/3, but the exemption is specific. Verify with the Charitable Trust Bureau before claiming it; rejected exemption claims result in retroactive registration requirements.
How GrantPipe Supports This Workflow
GrantPipe’s grant calendar deadline alerts keep AG990-IL and other state filings visible alongside funder reporting deadlines. Restricted fund tracking keeps grant revenue separated for the financial attachments. The grant compliance checklist consolidates the recurring filings into a single tracker.
For broader Illinois compliance, the Illinois nonprofit startup guide covers formation, and the Illinois AG990-IL filing guide walks through the annual filing in detail.
Start a free trial to wire AG990-IL deadlines into the same calendar as your active grant reports and federal filings.
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A practical checklist for post-award grant compliance: restricted funds, reporting cadence, audit prep, and common failure points. Delivered by email.
- Charitable Trust Bureau
- The Illinois Attorney General office unit administering charitable organization registration and oversight under the Charitable Trust Act (760 ILCS 55) and Solicitation for Charity Act (225 ILCS 460).
DEFINITION
- Form CO-1
- Charitable Organization Registration Statement. Initial registration form filed with the Illinois AG Charitable Trust Bureau. $15 fee.
DEFINITION
- Form AG990-IL
- Illinois Charitable Organization Annual Report. Filed annually with the Illinois AG Charitable Trust Bureau, due 6 months after fiscal year end. Includes attached IRS Form 990 and audit or review at threshold.
DEFINITION
- Solicitation for Charity Act
- Illinois statute (225 ILCS 460) governing charitable solicitation registration, disclosure, and enforcement.
DEFINITION
“Illinois's six-month AG990-IL deadline is the trap for organizations expanding from other states. The team calendars off May 15 by habit and misses June 30 entirely.”
“The $300,000 audit threshold is one of the lower thresholds in the country. Plan for CPA engagement well before the organization crosses $250,000 — auditor capacity is tight.”
Q&A
When is the AG990-IL due?
Six months after fiscal year end. For calendar-year filers, the deadline is June 30.
Q&A
Who needs to file CO-1?
Any charitable organization soliciting contributions in Illinois, regardless of state of incorporation. Out-of-state nonprofits soliciting Illinois donors must register too.
Frequently asked