NYS CHAR500 Filing: A Step-by-Step Compliance Route
For New York nonprofits, the CHAR500 is no longer a paper exercise that can be assembled, signed, and mailed from the executive director’s desk.
NYS CHAR500 Filing: A Step-by-Step Compliance Route
Since September 19, 2022, every registered charitable organization in New York State has been required to submit its annual CHAR500 through the Attorney General’s online portal. Paper submissions are not accepted.
That change matters well beyond the final click on the “submit” button. It affects who must have portal access, which officers must sign, how the financial statements are prepared, and how early the organization needs to begin coordinating with its CPA. A filing calendar built around paper forms or a single executive sign-off is not simply old-fashioned; it may leave out steps that are now part of the submission itself.
The CHAR500 is the annual reporting instrument required under Executive Law §172-b. It brings together financial disclosures, organizational attestations, registration information, and fee payments for charities registered with the New York State Charities Bureau. For New York City nonprofits — from small community land trusts and neighborhood arts organizations to established human-service providers with substantial operating budgets — it remains one of the central points of contact with state oversight.
The major changes relevant to the current route were adopted in 2021 and 2022. They include mandatory online filing, a higher threshold for the full CPA audit requirement, and the repeal of the duplicate Department of State filing for organizations registered under Article 7-A. Each change affects a different part of the annual process. Taken together, they require organizations to revisit filing calendars, approval workflows, and internal procedures.
A CHAR500 filing is not one form with one signature. It is a coordinated process involving registration status, financial reporting, fees, and two separate electronic attestations.
The Shift to Mandatory Online Filing and Electronic Signatures
The Charities Bureau’s online portal now handles CHAR500 submissions. Organizations that previously kept a paper packet in their annual compliance file must adapt that packet to an electronic workflow. The change applies to small organizations as well as larger institutions; limited administrative or technical capacity does not create a separate paper route.
The online submission requires two distinct electronic signatures:
1. Officer attestation — completed by the president, chief executive officer, or another authorized organizational officer.
2. Financial officer attestation — completed by the chief financial officer, treasurer, director of finance, or another person authorized to attest to the organization’s financial information.
These are separate functions, even when one person holds more than one title. In a small nonprofit, the executive director may also serve as treasurer, or the board treasurer may be closely involved in preparing the financial statements. The organization still needs to follow the portal’s signature requirements and make sure the appropriate individual can complete the relevant attestation.
The practical issue is often access rather than the form itself. Portal credentials are connected to the organization’s profile and to the individuals authorized to act for it. A new treasurer who has not yet been added to the organization’s account cannot necessarily solve the problem on the filing deadline. The same is true when a former officer remains associated with the profile or when the organization has changed its contact information without updating its state records.
A sensible internal sequence is:
1. Confirm the organization’s registration category and portal profile.
2. Identify the officer who will complete the organizational attestation.
3. Identify the financial officer who will attest to the reported financial information.
4. Check that both individuals have the necessary access before the filing window becomes tight.
5. Prepare the financial report and supporting documents before beginning the final online submission.
6. Preserve the submission confirmation and a copy of the completed filing in the organization’s compliance records.
This is especially important for organizations with fiscal years that end near a busy grant-reporting or audit season. The CHAR500 may be an annual filing, but it competes for the same staff time as the federal Form 990, board meetings, financial statement preparation, and funder reporting.
The two-signature structure also creates a useful governance checkpoint. The officer attestation and the financial officer attestation should not be treated as interchangeable clicks. They represent two related but distinct confirmations: one from the person authorized to speak for the organization and one from the person responsible for the accuracy of its financial reporting.
Navigating Financial Reporting Thresholds: From Unaudited to CPA Audits
The financial report accompanying the CHAR500 depends on the organization’s gross annual revenue and support. The thresholds were updated effective July 1, 2021, and the most significant change for many mid-sized nonprofits was the increase in the threshold for a full independent CPA audit.
| Gross annual revenue and support | Financial report generally required |
|---|---|
| Under $250,000 | Unaudited financial report |
| $250,000 to $1,000,000 | Independent CPA review report |
| Over $1,000,000 | Independent CPA audited financial statements |
The full audit threshold increased from $750,000 to $1,000,000. That means an organization reporting $900,000 in gross annual revenue and support may fall within the CPA review category rather than the full audit category, assuming the organization’s figures and registration circumstances place it within that tier.
A CPA review is not the same as an audit. A review generally involves analytical procedures and inquiries of management, while an audit involves a broader attestation process and a higher level of assurance. The distinction affects the engagement letter, the information requested from staff, the board’s review of the results, and the time needed to finalize the filing package.
Gross revenue is not the same as the annual budget
The relevant measurement is gross annual revenue and support, not the organization’s projected budget, net income, or the amount ultimately available for programs. A nonprofit can finish the year with a balanced budget or a deficit and still fall into a reporting tier based on its gross receipts and support.
Classification questions can arise around grants, contributions, special events, investment income, program service revenue, and amounts received for restricted purposes. A grant that is reported as revenue for the fiscal year may affect the applicable reporting threshold even if the related program spending occurs later. The organization should reconcile the amount used for CHAR500 purposes with the financial statements and with the CPA’s determination rather than relying on an internal budget figure.
That reconciliation is worth doing before the engagement is finalized. If the organization assumes that it is below the audit threshold and later discovers that the relevant gross figure places it above the threshold, the CPA engagement may need to be expanded. Conversely, an organization that treats every year as an audit year without checking the applicable threshold may commit resources to a more extensive engagement than the state filing requires.
Build the financial-reporting timeline backward
The filing deadline is not the date on which the financial work begins. A practical timeline runs in the opposite direction:
1. Close the fiscal year and reconcile the books. Revenue, support, liabilities, restricted funds, and related-party transactions should be sufficiently organized for the financial reporting process.
2. Confirm the applicable reporting tier. Use gross annual revenue and support, not a rough estimate of program spending or net assets.
3. Engage the CPA when a review or audit is required. The engagement should begin early enough to leave room for questions, corrections, and board review.
4. Circulate draft financial statements internally. Management and the finance committee should have an opportunity to identify classification issues and unresolved items.
5. Obtain the final signed CPA report, if applicable. The report must be ready to attach or otherwise submit with the CHAR500 package.
6. Complete the online filing and preserve the record. Save the final submission, supporting financial report, signatures, fee information, and confirmation.
For a calendar-year organization filing under Article 7-A, the default deadline is May 15. That places the filing only a few months after the December 31 year-end. Organizations with more complex finances, multiple programs, restricted grants, or outside bookkeeping support should treat the CPA engagement as part of the CHAR500 calendar rather than as a separate project.
The same discipline applies to smaller nonprofits. An organization that falls below the CPA review threshold may still need to produce a clear unaudited financial report and accurately complete the financial sections of the CHAR500. “Unaudited” does not mean “unchecked.” It means the report is not accompanied by the specified independent CPA review or audit.
Deadlines, Automatic Extensions, and the Repeal of Duplicate Filings
The filing deadline depends on the organization’s registration category.
- Article 7-A registrants and dual registrants — organizations registered under both Article 7-A and the Estates, Powers and Trusts Law — generally file by the 15th day of the fifth month after the end of the fiscal year.
- EPTL-only registrants generally file by the last day of the sixth month after the end of the fiscal year.
For a calendar-year filer, that means a May 15 deadline for an Article 7-A or dual registration and a June 30 deadline for an EPTL-only registration.
The Charities Bureau provides an automatic 180-day extension. The organization does not need to submit a written extension request, send an email, or file a separate extension form. The extension runs from the original deadline.
An automatic extension is useful, but it should not be mistaken for a reason to leave the filing untouched until the end of the additional period. The organization still needs to coordinate its CPA, confirm its fee or exemption status, secure both electronic signatures, and resolve any portal-access problems. A late start simply moves the same work into a narrower and more stressful window.
Fee treatment should also be checked separately. The extension changes the filing timetable, but it does not necessarily answer every question about when a fee must be paid or how an exemption should be claimed. The CHAR500 presents filing information and fee information through the same submission path, but the applicable treatment can depend on registration category and the exemption claimed.
The duplicate Department of State filing
Before November 12, 2021, nonprofits registered under Article 7-A had an additional administrative step: filing a duplicate CHAR500 with the New York State Department of State. That duplicate requirement was eliminated when Governor Hochul signed bill S4817/A1141.
The change removed one filing from the annual calendar. Organizations no longer need to prepare a second version of the CHAR500 for that Department of State submission or maintain a separate confirmation for the repealed filing.
This is a small change in the abstract, but it has real consequences for internal procedures. Many nonprofits run their annual compliance process through recurring calendar entries, shared spreadsheets, board packets, or task-management software. A procedure created before the repeal may still generate a Department of State reminder even though the step is no longer part of the filing route.
The correction is straightforward:
- remove the duplicate Department of State submission from the annual calendar;
- retain the current Charities Bureau submission as the state charitable filing;
- update board and finance committee materials that describe the process;
- check old templates before copying them into the next filing cycle; and
- make sure staff do not confuse the repealed duplicate with other state or federal obligations that remain separate.
The repeal does not eliminate the CHAR500. It eliminates a second submission of the same annual charitable report.
Privacy Updates: The Suspension of IRS Schedule B Donor Disclosures
Schedule B to IRS Form 990, the Schedule of Contributors, contains donor information that can include names, addresses, and contribution amounts for donors meeting the applicable federal reporting criteria. That donor-level schedule was previously part of the CHAR500 submission requirements. Its submission has been suspended.
For the state filing, the practical instruction is clear: organizations should not attach Schedule B to the CHAR500 unless the Charities Bureau issues updated guidance requiring it. The fact that Schedule B may be prepared for the organization’s federal Form 990 does not, by itself, mean that the same schedule belongs in the state filing package.
This distinction matters because the federal and state filings have different purposes and disclosure frameworks. A nonprofit may need to complete Schedule B for federal reporting while excluding it from the CHAR500 submission. Staff preparing the two filings should keep the packages separate rather than treating the federal Form 990 attachments as a single group that can be uploaded without review.
The suspension also calls for care in document management. Donor schedules should be stored with the federal return and shared only with people who need access for that filing. They should not be placed in a general CHAR500 folder or uploaded to the state portal as an “extra” attachment. An unnecessary attachment can disclose more information than the state filing requires.
The legal and policy background involves broader questions about compelled disclosure of donor identities in the charitable context. For day-to-day compliance planning, however, the organization does not need to resolve every constitutional or policy question before filing. It needs to distinguish the documents required for the CHAR500 from those prepared for other reporting obligations and monitor formal guidance for any change.
Keep the federal Schedule B and the state CHAR500 package separate. A document prepared for one filing does not automatically belong in the other.
The suspension is not a license to stop reviewing the filing instructions. It is a reason to make the review deliberate. Before submission, the staff member assembling attachments should compare the package with the current Charities Bureau requirements and remove donor-level schedules that are not required.
Fee Structures for Article 7-A and EPTL Registrants
The filing fee depends on the organization’s registration classification. For EPTL registrants, the fee also depends on reported net worth.
Article 7-A registrants
- Standard filing fee: $25
- An exemption may be available under Part 3a of the CHAR500 for qualifying organizations.
EPTL registrants
- Filing fee: $25 to $1,500, based on the organization’s reported net worth
- An exemption may be available under Part 3b for qualifying organizations.
The EPTL fee is graduated rather than uniform. The CHAR500 uses the organization’s reported net worth to determine the applicable amount, with the lowest tier beginning at $25 and the highest tier reaching $1,500.
| Registration or financial factor | What it affects |
|---|---|
| Article 7-A registration | Standard Article 7-A fee and possible Part 3a exemption |
| EPTL registration | Fee based on reported net worth and possible Part 3b exemption |
| Dual registration | The organization must address both registration categories in the same filing |
| Claimed exemption | The organization must complete the applicable exemption section and satisfy its conditions |
Dual registrants should not assume that one fee selection resolves both registration categories. The CHAR500 captures the relevant information in its respective sections, and the organization must complete the form according to its actual registration status.
Exemptions also require affirmative action. An organization claiming an exemption under Part 3a or Part 3b should complete the applicable portion of the CHAR500, review the eligibility criteria, and make sure the required attestations and selections are present. A blank box, missing signature, or incomplete exemption section can create a problem even when the organization would otherwise qualify.
The person reviewing the fee section should compare it with the organization’s registration records and financial information. A nonprofit may have changed its activities, legal structure, or registration status since the prior filing. Reusing last year’s fee selection without checking the current form can carry an old assumption into a new filing.
What Belongs in the Filing Package
The exact submission will depend on the organization’s registration status and financial reporting tier, but the CHAR500 process generally requires the following components:
1. A completed CHAR500 form. All sections applicable to the organization’s registration category should be addressed.
2. The authorized officer’s electronic signature. This is generally completed by the president, CEO, or another authorized officer.
3. The financial officer’s electronic signature. This is completed by the CFO, treasurer, director of finance, or another authorized financial officer.
4. The appropriate financial report. Depending on gross annual revenue and support, this may be an unaudited report, an independent CPA review report, or independent CPA audited financial statements.
5. The applicable filing fee. If the organization qualifies for an exemption, the relevant exemption section must be completed instead of simply omitting the fee.
6. The federal Form 990, where required as part of the state submission. The federal return and state filing should be coordinated, but their attachments should not be treated as identical.
7. The filing confirmation and retained copy. The organization should keep evidence of what was submitted, when it was submitted, and which financial documents were included.
Schedule B should not be included unless updated Charities Bureau instructions expressly require it. The organization should also avoid uploading documents merely because they were available during preparation. The filing package should contain what the state process calls for, not every internal worksheet, donor schedule, draft statement, or board document generated during the year.
That principle is particularly important for organizations using outside bookkeepers, grant consultants, or shared administrative platforms. Several people may contribute to the filing, but one person should be responsible for reviewing the final package before submission. The final reviewer should confirm that the correct fiscal year is selected, the registration category is accurate, the financial report matches the organization’s figures, the fee or exemption is addressed, and both signatures are complete.
Keeping the Annual Compliance Route Current
The organization’s internal procedure should reflect the current filing route rather than preserve every step from earlier versions of the process. A useful internal review focuses on the points that can change the outcome of the filing:
- Filing method: The CHAR500 is submitted online through the Charities Bureau portal; paper submission is not the route for the annual filing.
- Signatures: Two electronic attestations are required, one from an authorized officer and one from a financial officer.
- Financial threshold: The full independent CPA audit threshold is $1,000,000 in gross annual revenue and support.
- CPA review tier: Organizations in the $250,000-to-$1,000,000 range generally provide an independent CPA review report.
- Unaudited tier: Organizations under $250,000 generally provide an unaudited financial report.
- Extension: An automatic 180-day extension is available without a written request.
- Duplicate Department of State filing: The duplicate Article 7-A submission was repealed and should not remain in the annual workflow.
- Schedule B: Donor-level Schedule B information is suspended from the CHAR500 package unless current state guidance says otherwise.
- Article 7-A fee: The standard fee is $25, subject to an available Part 3a exemption.
- EPTL fee: The fee ranges from $25 to $1,500 based on net worth, subject to an available Part 3b exemption.
- Article 7-A and dual registration deadline: The 15th day of the fifth month after the fiscal year-end.
- EPTL-only deadline: The last day of the sixth month after the fiscal year-end.
These points are more useful when connected to named responsibilities. The compliance calendar should identify who confirms the fiscal year-end, who requests the CPA engagement, who prepares the form, who reviews the fee or exemption, who obtains each electronic signature, and who saves the confirmation. A deadline without an owner is only a date on a calendar.
The procedure should also include a short post-filing review. After submission, the organization can record the confirmation number, save the final documents, note any technical or substantive issue encountered, and update the next year’s calendar while the process is still fresh. If the treasurer needed portal access, if a financial classification required CPA clarification, or if an exemption section caused confusion, that information belongs in the organization’s internal notes.
The changes from 2021 and 2022 therefore have an operational consequence beyond the individual rule changes. They require a filing route that begins with registration status and fiscal-year timing, moves through financial reporting and fee analysis, and ends with a properly authorized online submission. Updating the process is not about adding bureaucracy. It is about making sure the organization’s records, people, and documents arrive at the same filing at the same time.
For NYC nonprofits, the most reliable approach is to treat the CHAR500 as a recurring compliance project rather than a form completed at year-end. Confirm the reporting tier early, engage the CPA when required, check portal access before the deadline, separate federal donor schedules from state attachments, and remove the repealed duplicate filing from old procedures. The result is a filing calendar that reflects the rules actually governing the submission — and a compliance record that can be explained to the board, the finance committee, and the next person who inherits the process.