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Michigan Charitable Registration Workflow: CTS-01 Through CTS-02

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TLDR

Charitable organizations soliciting in Michigan must register with the Attorney General's Charitable Trust Section using Form CTS-01 before solicitation begins, and renew annually with Form CTS-02 within 7 months after fiscal year end. Audit and review thresholds are revenue-driven, similar to other states. Michigan also requires an annual LARA nonprofit report - a separate, often-missed filing due October 1 each year. Both calendars must be tracked.

The Michigan charitable registration workflow has two parallel calendars: the Attorney General’s Charitable Trust Section (CTS-01 and CTS-02) and LARA’s annual nonprofit report. Both must be tracked. This workflow covers the operational sequence.

When CTS-01 Is Required

The trigger for Michigan charitable registration is solicitation activity directed at Michigan residents - direct mail, email, online giving forms, events, telephone, in-person. Holding charitable assets in Michigan also triggers registration.

If any apply, file CTS-01 before solicitation begins. Soliciting before registration is a violation, and many foundation funders verify Charitable Trust Section registration before issuing grants.

Initial Registration: CTS-01

The CTS-01 packet includes:

  • Completed CTS-01 form
  • Articles of Incorporation
  • Bylaws
  • IRS Form 1023 (or determination letter, if issued)
  • Most recent Form 990 if available
  • Officer and director list
  • Sliding fee (often $0 for small organizations)

Processing typically runs 30 to 60 days. Complete filings move faster.

Annual Renewal: CTS-02

Once registered, the organization files CTS-02 every year, due 7 months after fiscal year end:

  • December fiscal year †’ July 31
  • June fiscal year †’ January 31
  • September fiscal year †’ April 30 of the following year

The fee scales with revenue. Submit through the Michigan AG’s online portal or by mail.

Audit Attachment Thresholds

The CTS-02 attachment requirement is generally tied to gross contributions:

  • Below $500,000 †’ Form 990/990-EZ/990-N only
  • $500,000 to $1 million †’ CPA review
  • Above $1 million †’ Full CPA audit

Confirm current thresholds with the Charitable Trust Section before each filing cycle, as they may be updated.

The Parallel LARA Calendar

Independent of the AG calendar, every Michigan nonprofit corporation must file an annual report with LARA by October 1 each year. The fee is $20. The filing updates officer and director information.

This is the failure mode for Michigan nonprofits: the AG calendar is tracked, the LARA calendar is not. After two years of LARA non-filing, the corporation can be administratively dissolved - which voids contracts, terminates grant eligibility, and is publicly visible.

Suspension and Reinstatement

Late filings escalate this way:

  • CTS-02 late †’ AG sends delinquency notice †’ continued non-compliance suspends solicitation rights
  • LARA report late †’ LARA marks corporation in default †’ after 2 years, administrative dissolution

Reinstatement after CTS-02 delinquency requires filing the missing CTS-02 forms with attachments. Reinstatement after LARA dissolution is more involved - file the missing reports, pay penalties, and request reinstatement under the Nonprofit Corporation Act.

Tracking Both Calendars

Most organizations track these alongside grant deadlines in a compliance calendar:

  • IRS Form 990 deadline
  • CTS-02 deadline (7 months after FYE)
  • LARA annual report (October 1)
  • Sales tax filings (if applicable)
  • Grant-specific reporting deadlines

For the broader formation context that precedes this workflow, see the Michigan nonprofit startup guide.

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Michigan charitable registration is administered by the Attorney General's Charitable Trust Section under the Charitable Organizations and Solicitations Act.

Source: Michigan Attorney General Charitable Trust Section

Michigan nonprofit corporations must file an annual report with LARA by October 1 each year, with a $20 fee.

Source: Michigan LARA Corporations Division

Michigan Articles of Incorporation for a nonprofit corporation cost $20 to file with LARA.

Source: Michigan LARA

DEFINITION

Charitable Trust Section
The unit within the Michigan Attorney General's office that administers charitable registration under the Charitable Organizations and Solicitations Act and the Supervision of Trustees for Charitable Purposes Act.

DEFINITION

CTS-01
Initial Solicitation Registration. Filed once, before solicitation begins in Michigan.

DEFINITION

CTS-02
Annual Renewal of Solicitation Registration. Due 7 months after fiscal year end. Includes financial summary and (depending on revenue) attached audit or review.

DEFINITION

LARA Annual Report
Annual filing with the Michigan Department of Licensing and Regulatory Affairs Corporations Division. Due October 1. Required for all Michigan nonprofit corporations regardless of solicitation status.

DEFINITION

Administrative dissolution
LARA-initiated termination of corporate existence triggered by chronic non-filing of the annual report. Restoration requires bringing all delinquent reports current plus penalties.
“Michigan's two-track system - AG for solicitation, LARA for corporate status - is the structural feature that catches founders. They register with one, miss the other, and get a dissolution notice in year three.”

Compliance practitioner , Michigan nonprofit fiscal officer
“The October 1 LARA deadline is independent of the fiscal year. Even if your fiscal year ends June 30, the LARA report is October 1 of every calendar year. That offset is what surprises people.”

Compliance research synthesis , Builder perspective at GrantPipe

Q&A

How do I register a charity in Michigan?

File Form CTS-01 with the Michigan Attorney General's Charitable Trust Section, attaching the Articles of Incorporation, bylaws, IRS Form 1023 or determination letter, most recent Form 990 if available, and officer/director list. Submit online or by mail.

Q&A

What is the difference between CTS-01 and CTS-02?

CTS-01 is the one-time initial registration filed before solicitation begins. CTS-02 is the annual renewal filed every year afterward, due 7 months after fiscal year end.

Frequently asked

Frequently Asked Questions

What is the CTS-01?
The Initial Solicitation Registration form filed with the Michigan Attorney General's Charitable Trust Section. Required before any charitable solicitation begins in Michigan.
When is the CTS-02 due?
Seven months after the close of the organization's fiscal year. For a December fiscal year, July 31. For a June fiscal year, January 31. Extensions are available but must be requested before the original deadline.
What revenue triggers a Michigan audit requirement?
Generally, contributions above $500,000 trigger a CPA review requirement, and contributions above $1 million trigger a full CPA audit attached to the CTS-02. Confirm current thresholds with the Michigan AG before each filing.
Are religious organizations exempt from Michigan charitable registration?
Some are. Houses of worship and certain religious activities qualify for exemption under the Charitable Organizations and Solicitations Act, but the exemption is narrow. Religious nonprofits with broader public-facing activities often must register.
Do I need to file CTS-02 if our revenue is under $25,000?
Yes. There is no broad revenue exemption from registration itself. Small organizations may have reduced fees or simpler reporting, but registration requirements apply once solicitation has begun.
What is the Michigan annual nonprofit report and how does it relate to CTS-02?
The annual nonprofit report is a separate filing with LARA, due October 1 each year. It updates corporate information. CTS-02 is filed with the Attorney General and reports financial information. Both are required and tracked separately.

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