This is Part 4 of our California Nonprofit Law Essentials series, where we’ve been walking through the legal steps every California nonprofit must take to start strong, and then remain compliant and credible.

In Part 1, we introduced the big picture of nonprofit law in California. In Part 2, we explored the requirements of forming a nonprofit under California law. In Part 3, we explained the IRS process for securing federal tax-exempt status.

Now, in Part 4, we turn to California Charitable Registration—a step that ensures your nonprofit is not only incorporated and tax-exempt, but also legally authorized to solicit donations and hold charitable assets in California.

The Attorney General’s Oversight of Charitable Organizations

California has one of the most robust regulatory systems for nonprofits in the country. By law, the Attorney General has primary oversight of all charitable corporations, charitable trusts, fundraising professionals and fundraising platforms operating in the state. This responsibility is rooted in the idea that charitable assets—whether a $50 check from a local donor or a multi-million-dollar foundation grant—are held in trust for the public benefit.

The Attorney General enforces this public trust through the Registry of Charities and Fundraisers, which monitors thousands of nonprofits statewide. Oversight includes reviewing annual filings, auditing organizations suspected of misuse, and investigating cases of fraud, diversion of assets, or self-dealing.

Practically, this means the Registry isn’t just a filing cabinet for paperwork—it’s an enforcement tool. Organizations that fall behind on their filings or misuse charitable assets may face:

  • Fines and penalties,
  • Suspension of fundraising rights,
  • Revocation of state tax exemptions, and in serious cases,
  • Litigation to recover charitable assets or dissolve the nonprofit entirely.

For everyday nonprofits, this oversight is felt most directly through the requirement to register and renew annually. A failure to do so can quickly result in fines, suspension of your ability to raise funds, and a “delinquent” label in the Registry’s public database—an outcome that can damage credibility with donors and grantmakers.

It’s important to note that not every nonprofit in California is required to register with the Attorney General. Mutual benefit corporations that are not organized as charities—such as trade associations, professional groups, and social clubs—are generally exempt because their activities are designed to benefit their members, not the public at large. Similarly, religious corporations formed under California’s Nonprofit Religious Corporation Law are not required to register. That’s because the Attorney General’s supervisory authority extends only to assets held in charitable trust for the public benefit, and religious corporations are recognized under state law as distinct from charitable corporations. In short, charitable registration applies to organizations holding assets for public, charitable purposes, but not to nonprofits formed for religious or strictly mutual benefit purposes.

Getting Started: The Initial Registration

Once your nonprofit receives charitable assets—whether that’s a first donation, a grant, or startup funds—you must register within 30 days. This begins with Form CT-1, Initial Registration Form, filed with the Registry of Charities and Fundraisers.

The CT-1 must be accompanied by:

  • Your IRS determination letter (if you have it).
  • Your Articles of Incorporation.
  • Your bylaws.
  • Your most recent IRS Form 990, 990-EZ, or 990-PF. If you haven’t yet filed a return, you must submit a balance sheet and statement of revenue and expenses instead.
  • The required initial registration fee.

Once approved, your organization will be listed in the public Registry of Charities and Fundraisers, where anyone—from donors to journalists to watchdog groups—can look up your compliance status. For compliant nonprofits, this listing is a badge of legitimacy. For those who fall behind, a “delinquent” designation sends the opposite message.

Annual Renewal and Oversight

Filing the initial CT-1 is just the beginning. Each year, California nonprofits must renew their registration with the Attorney General by submitting Form RRF-1, Annual Registration Renewal Fee Report. The renewal is due four months and fifteen days after the close of the fiscal year, which typically coincides with federal IRS filing deadlines. The required fee is typically modest, ranging from $25 for the smallest nonprofits, but the top tier fee is $1,200 for those with the largest revenues in excess of $500 million.

The specific documents you must provide depend on your organization’s size. Smaller nonprofits that qualify to file the federal 990-N postcard must also submit Form CT-TR-1, the Annual Treasurer’s Report. Because the 990-N contains almost no financial detail, the CT-TR-1 supplies the missing information, outlining the nonprofit’s income, expenses, and assets for the year.

Mid-sized organizations generally attach their IRS Form 990-EZ with the RRF-1, while larger organizations submit the full IRS Form 990. Those with revenues in excess of $2 million are further required to provide audited financial statements prepared by an independent accountant.

In addition to requiring financial information, the RRF-1 asks a series of yes-or-no questions that reflect the Attorney General’s core oversight priorities. These aren’t incidental; they go straight to the issues that most often undermine public trust in charitable organizations.

The form begins by asking whether there were any financial transactions between the nonprofit and its insiders—officers, directors, or trustees—or with entities in which they have an interest. This question is designed to highlight potential conflicts of interest or self-dealing, which are strictly regulated under California law.

The Attorney General also asks whether there has been any theft, embezzlement, diversion, or misuse of charitable funds. A “yes” answer here signals immediate concern and will almost certainly trigger follow-up review. Similarly, the form requires disclosure if nonprofit funds were used to pay fines, penalties, or judgments, since these payments may suggest compliance issues or misuse of resources.

Several of the questions focus on fundraising practices. Organizations must disclose whether they engaged the services of a commercial fundraiser, fundraising counsel, or commercial coventurer, whether they received government funding, and whether they conducted raffles or vehicle donation programs. Each of these activities carries its own compliance requirements, and the Attorney General uses these disclosures to monitor whether nonprofits are following the additional rules that apply to specialized fundraising.

Finally, the RRF-1 asks whether the organization conducted an independent audit and prepared audited financial statements (again, this is required if gross receipts exceeded $2 million), and whether it held restricted net assets while reporting negative unrestricted net assets at year-end. These questions go directly to financial health and transparency. They help regulators spot organizations that may be struggling or improperly balancing restricted versus unrestricted resources.

Together, these questions function as an annual checkpoint, reminding boards and executives of their fiduciary responsibilities. They also reinforce the broader principle behind California’s regulatory system: charitable assets belong to the public, and their stewardship must be transparent, responsible, and beyond reproach.

Beyond California: Fundraising in a National Landscape

The reach of the Attorney General’s authority is limited to California, but your nonprofit’s fundraising may not be. Even the smallest organizations often receive online gifts from out-of-state donors. And just as California requires registration before soliciting contributions here, most other states have similar laws.

Unfortunately, there is no single “national” registration system. Nonprofits must comply with each state’s rules individually, or in some cases, through the Unified Registration Statement, which can simplify—but not eliminate—the process. For organizations planning to expand their reach beyond California, compliance across jurisdictions should be part of the strategic plan from the very beginning.

Because this issue is so important, especially in today’s online fundraising environment, we’ll be devoting a future post in this series to the complexities of multi-state charitable solicitation and fundraising compliance.

The Big Picture

Charitable registration with the Registry of Charities and Fundraisers is not simply another administrative task to add to the checklist. It is the mechanism California uses to safeguard charitable assets and ensure that nonprofits fulfill their obligation to serve the public good. By keeping registration current, your organization demonstrates transparency, accountability, and respect for the trust placed in it by donors and the community.

When viewed alongside incorporation and federal tax-exempt status, charitable registration completes the legal foundation every nonprofit needs. Together, these steps create the framework that allows your board and leadership team to focus on mission, programs, and impact—confident that the compliance groundwork is secure.

In Part 5 of our California Nonprofit Law Essentials series, we’ll stay with the theme of state-level compliance and turn to the California Franchise Tax Board. Federal recognition from the IRS is only half the story—California has its own system for granting income tax exemption, and nonprofits must apply separately to secure it. We’ll walk through the application process, explain the difference between Forms 3500 and 3500A, and highlight common mistakes to avoid.

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