Rules
New York charity filings and the wording of the ask
The New York filing order for charities that solicit: CHAR410 before the first ask, CHAR500 after year end, and the Article 7-A wording the appeal must carry.
What to take away
- Register with the Attorney General's Charities Bureau before the first ask, then file an annual report after each fiscal year.
- Form CHAR500 is due within four and a half months of the fiscal year end, with Form 990 or 990-EZ attached.
- Article 7-A also controls the words in the askthe registration disclosure and the annual report line.
- Groups that raise under $25,000 a year with volunteers generally fall outside registration, until a paid professional runs the appeal.
- IRS substantiation and quid pro quo rules apply on top of the state filings.
Registration comes before the first ask
Registration comes first. Any group that asks New Yorkers for money must register with the Charities Bureau of the New York State Attorney General's Office, and it must do so before the first solicitation, not after it.
Form CHAR410 is the registration statement. It asks for the IRS determination letter, the governing documents and a list of officers. Because the Charities Bureau publishes filings, donors and reporters can read them. Make registration the first gate on your campaign checklist.
Another state's file does not carry over. Texas charities register through a different office, so a team that mobilizes donors in both states keeps two registration files and two calendars.
The annual report and the federal return
Form CHAR500 is due within four and a half months of the fiscal year end and carries Form 990 or 990-EZ as an attachment. Smaller groups file a simplified version. Put the date in the calendar when the fiscal year closes, not when a reminder arrives.
The federal return runs on a similar clock. The IRS says Form 990 or 990-EZ must be filed by the 15th day of the 5th month after the end of the accounting period, so one set of year-end numbers feeds both filings.
New York Filing Requirements
Registration
- Form
- CHAR410
- Deadline
- Before first solicitation
- Attachment
- IRS letter, governing docs
Annual report
- Form
- CHAR500
- Deadline
- 4.5 months after FY end
- Attachment
- Form 990 or 990-EZ
Federal return
- Form
- 990/990-EZ/990-N
- Deadline
- 15th day of 5th month
- Attachment
- None
| Filing | Form | Deadline |
|---|---|---|
| Registration | CHAR410 | Before the first solicitation |
| Annual report | CHAR500 | Four and a half months after fiscal year end |
| Federal return | Form 990, 990-EZ or 990-N | Fifteenth day of the fifth month |
What Article 7-A requires in the ask
Article 7-A reaches the wording of the appeal itself. Written appeals must state that the organization is registered with the Charities Bureau and that its annual report is available on request. Check that line in every written template before it goes out.
Article 7-A Ask Requirements
- State Charities Bureau registration in written appeals
- Offer annual report on request
- Register professional fundraisers separately
- File paid solicitor contracts with state
- Disclose share of gross receipts reaching charity
- Volunteer exemption ends with paid professional
Professional fundraisers and solicitors register separately, and their contracts are filed with the state. When a paid solicitor makes the ask, the script states the share of gross receipts that reaches the charity. Keep both records beside the registration.
The ask is a legal document in New York. The disclosure line belongs in the copy, not in fine print at the page bottom.
Who can skip registration
Groups that raise under $25,000 a year with volunteers generally fall outside registration. That exemption ends once a paid professional runs the appeal, so a volunteer group should register before it pays anyone to run an ask.
The exemption is narrow. A group near the $25,000 line should treat registration as the plan and the exemption as the exception, because the filing has to be in place before the first solicitation.
IRS rules that travel with the ask
IRS rules follow the donor, not the state line. A written acknowledgment is required for any single contribution of $250 or more, and it must state whether goods or services were provided. The IRS explains these duties in its guidance on substantiation and disclosure requirements.
IRS Substantiation Thresholds
- $250Written acknowledgment required
- $75Quid pro quo statement required
- 501(h)Lobbying expenditure test election
- 501(c)(3)Campaign intervention barred
Quid pro quo contributions over $75 need a written statement of the value of what the donor received. A gala ticket or a tote bag counts as a benefit, so the acknowledgment splits the gift from the premium.
Lobbying must stay insubstantial unless the group elects the expenditure test under section 501(h). Campaign intervention is barred outright for 501(c)(3) organizations, in email, in ads and at events. Neither rule changes the state filings, but both belong in the same review before the appeal goes out.
A spring appeal in four steps
A Brooklyn food pantry registered in New York wants to reactivate 4,000 lapsed donors before June. Four steps keep the appeal inside both sets of rules, and the order follows the filings above, so nothing goes out before its paperwork exists.
Spring Appeal Compliance Sequence
- Check Charities Bureau registration and last CHAR500
- Put disclosure line and address in email footer
- Split list by last gift date
- Send separate acknowledgment for $250+ donors
- Keep reply copy for annual filing and grants
- Confirm the registration is active before the first send.
- Put the registration disclosure and the annual report line in the copy.
- Split any premium from the gift in the acknowledgment, and state whether goods or services were provided.
- Keep the appeal and its follow-up clear of campaign activity.
Email and donor data
Email reactivation counts as solicitation, so the disclosure habits above apply to every send, not just to the first mailer. Solicitation covers email, social posts, phone calls and events, not just mail.
Donor records add a second layer. New York's SHIELD Act expects reasonable safeguards for private data, and the state privacy statutes vary enough that one donation form can fall under several regimes.
