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California Multi-State Fundraising Compliance Guide

Last Updated: February 2026

California is one of the most administratively demanding charitable registration jurisdictions in the country. Unlike most states, California’s registration requirement is triggered by the receipt of charitable assets, not merely the act of solicitation.

For national nonprofits, California should be treated as a high-priority compliance state due to:

  • Annual reporting complexity
  • Sliding-scale renewal fees
  • Audit thresholds
  • Separate corporate qualification requirements
  • State tax implications

For broader national planning, see:

When Registration Is Required in California

A nonprofit must register with the California Attorney General’s Registry of Charities and Fundraisers within 30 days of initially receiving charitable assets in California.

This differs from most states, which require registration before solicitation.

Out-of-state nonprofits must register if they:

  • Hold charitable property in California
  • Solicit California residents
  • Maintain offices or employees in California
  • Conduct board meetings in California
  • Operate charitable programs in California

If a nonprofit’s only contact with California is making grants into the state or maintaining financial accounts, registration may not be required.

Organizations fundraising online should review:

Initial Registration Overview

California registration is valid for one year.

Initial filing typically requires:

  • Initial Registration Form (CT-1)
  • Governing documents
  • IRS determination letter
  • IRS Form 1023 or 1024 (if available)
  • List of officers and directors
  • Filing fee

Initial Filing Fee: $50

California does not require a registered agent for charitable registration purposes.

However, foreign nonprofits must separately qualify to do business with the Secretary of State if engaging in intrastate business (see below).

For timing strategy, see:

Corporate Qualification and State Tax Considerations

California is unique in that charitable registration and corporate qualification are distinct processes.

Corporate Qualification

Out-of-state nonprofits that conduct intrastate business must:

  • File for a Certificate of Qualification with the California Secretary of State
  • Appoint an agent for service of process

This is separate from charitable registration.

California Franchise Tax

Nonprofits receiving money or property in California may be subject to the state’s minimum franchise tax unless they obtain state tax-exempt recognition.

This is frequently overlooked in multi-state compliance planning and should be coordinated at the CFO level.

Exemptions

California provides limited exemptions and does not offer a small charity exemption.

Exempt organizations generally include:

  • Religious corporations holding property for religious purposes
  • Certain nonprofit educational institutions
  • Certain nonprofit hospitals
  • Governmental entities
  • Political committees reporting to state authorities

Unlike many states, even very small charities may be required to register.

For broader exemption strategy, see:

Annual Renewal and Financial Reporting

California requires annual renewal filings.

Due Date:
4½ months after the close of the fiscal year.

An automatic six-month extension is available if the organization files an IRS extension.

Renewal Filing Components

  • Annual Registration Renewal Fee Report (RRF-1)
  • IRS Form 990 (990, 990-EZ, or 990-PF)
  • Audited financial statements if revenue exceeds $2 million (excluding certain government grants)
  • Additional reports for organizations with substantial California fundraising activity

Renewal Fees (Sliding Scale)

California renewal fees are based on gross annual revenue, ranging from $25 to $1,200.

Late Filing Consequences

California imposes significant penalties for delinquent filings, including:

  • Monthly late fees
  • Potential suspension of state tax-exempt status
  • Possible personal liability exposure for officers and directors in certain circumstances

For national renewal coordination:

Disclosure Requirements

California does not impose a single universal disclosure statement comparable to Florida or New York. However, charitable sales promotions and commercial co-venture arrangements are regulated separately.

See:

Professional Fundraisers

Organizations that retain:

  • Professional solicitors
  • Fundraising counsel
  • Commercial co-venturers

must comply with additional reporting and contract filing requirements.

Relevant guidance:

Governance and Risk Considerations

California is considered a high-enforcement jurisdiction. Registration status is publicly searchable and frequently reviewed during:

  • Grant due diligence
  • Mergers or affiliations
  • Fiscal sponsorship transitions
  • Audit reviews
  • Form 990 compliance disclosures

See:

California in a National Compliance Strategy

For national nonprofits, California is typically among the most resource-intensive states to manage. The combination of:

  • Receipt-triggered registration
  • Corporate qualification requirements
  • Franchise tax considerations
  • Sliding-scale fees
  • Audit thresholds
  • Detailed annual reporting

makes centralized compliance oversight critical.

For broader planning:

If your organization is fundraising in California as part of a multi-state campaign, coordinated oversight significantly reduces administrative burden and governance exposure.

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