Important note: This article is general educational information, not legal, tax, or accounting advice. Confirm any requirement with the Illinois Attorney General’s Charitable Trust Bureau or a qualified professional before you rely on it.
The deadline for the Illinois AG990-IL annual report is not the hard part. The report is due six months after your fiscal year ends, and there are ways to get more time if you ask before the date.
The harder question is the document that has to travel with the report — whether that is a simple financial statement, a CPA’s review, or a full audit. The decision that moves an organization from one to another can be made months earlier, in a meeting about how to raise more money, by people who will not be the ones asked to produce the audit. If you are that person, this guide is written for you.
So this guide starts where that decision starts: with who raises the money.
Key takeaways
- Illinois charities register with the Attorney General before they solicit, then file an AG990-IL annual report each year, unless an exemption applies.
- If fundraising is done only by staff and unpaid volunteers, an audit is required above $500,000 in contributions. If it is not, the line is $25,000.
- “Contributions” counts the gross amounts the public pays for events and merchandise, not only donations.
- The report is due six months after year-end. An organization in good standing can get 60 more days by asking in writing before that date. A late report costs an extra $100.
- The 2024 changes that set the $500,000 line are written to stop applying on January 1, 2029.
On this page
- In Illinois, who raises the money sets the audit line
- Illinois charitable organization registration comes first
- What Illinois counts as contributions
- What has to go with the AG990-IL, by size
- The $25,000 line for paid fundraising
- When the AG990-IL is due, and how to get more time
- Filing online, and why complete matters
- The 2029 date written into the statute
- What to settle before your fiscal year closes
- Getting help with the annual report
- Sources reviewed
- Frequently asked questions
- Related NPO Resources guides
In Illinois, who raises the money sets the audit line
Illinois sets its audit line with a dollar figure, but it asks a second question first — who did the raising.
Section 4 of the Solicitation for Charity Act requires an independent CPA’s opinion with the annual report from two kinds of organization. The first receives contributions in excess of $500,000. The second is any organization whose fund raising functions are “not carried on solely by staff employees or persons who are unpaid for such services,” once its contributions pass $25,000.
A kitchen is a fair comparison. Cooking for a neighborhood potluck is one thing. Hire a caterer to feed the same people and a different set of rules applies — not because the food is different, but because someone is now being paid to serve it. The same meal, a different category.
That is why the $500,000 figure and the $25,000 figure are not two steps on one ladder. They are two different ladders, and which one your organization stands on depends on a staffing decision.
Watch: how hiring a fundraiser changes the audit line
Illinois
The deadline is ordinary. The attachment is not.
Illinois charitable organization registration comes first
Registration is handled by the Illinois Attorney General’s Charitable Trust Bureau. Every charitable organization that solicits or intends to solicit contributions from people in Illinois, or is located in Illinois, files a registration statement with the Attorney General “prior to any solicitation,” with a $15 fee. The order matters: the Attorney General’s registration instructions list a $200 late registration fee for an organization that solicits before it registers.
The registration package, per those instructions, is built from these documents:
Two exemptions are worth reading closely, because they exempt an organization from the report filing provisions and not from registering. Section 3 exempts religious organizations, and any organization that does not intend to receive, and does not actually receive, more than $15,000 in contributions in a 12-month period ending December 31. Either exemption applies only after the organization registers and the Attorney General confirms it. Both still register: the exemption applies “except for the requirements set forth in Section 2,” which is the registration section. Section 3 separately lists organizations that do not have to register at all, such as fraternal, patriotic, social, educational and alumni organizations and historical societies that solicit only their own members; see 225 ILCS 460/3.
If your organization also asks for donations in other states, our guide to charitable solicitation registration covers how the trigger differs from state to state.
What Illinois counts as contributions
Every threshold below is measured in “contributions,” and the Illinois definition is wider than the word suggests.
The AG990-IL instructions say contributions include the gross amounts of cash donations as well as “gross sums paid by the public for merchandise, special events, rights or services of the organization.” Gross means the whole amount paid, not the part left after costs.
Think of a bake sale. The number that counts is what buyers handed over for the cakes, not the margin after flour and sugar. In the same way, if a gala brings in $120,000 in ticket and sponsorship payments, that $120,000 goes into the total, even if the evening cost most of it to run.
The statute also sets out what does not count: union member dues and donated services — “donated services shall not be deemed contributions.” Volunteer hours, however valuable, stay out of the calculation. So do admission ticket sales by a 501(c)(3) music or theater organization that regularly presents live public performances — the statute excludes those from contributions.
What has to go with the AG990-IL, by size
Read the table by contributions received in the fiscal year. The “Staff and volunteers only” column applies when all fundraising is carried on by staff and unpaid volunteers.
| Contributions in the year | Staff and volunteers only | Paid fundraising involved |
|---|---|---|
| $15,000 or less | May be exempt from annual financial reports under Section 3, once the Attorney General confirms it. Registration still applies | Same exemption test |
| Over $15,000, up to $25,000 | Simplified summary: gross receipts, total disbursements, assets at year-end | Same |
| Over $25,000, up to $300,000 | AG990-IL financial report, no CPA involvement | Audit |
| Over $300,000, up to $500,000 | Reviewed financial statements from an independent CPA | Audit |
| Over $500,000 | Audit | Audit |
From 225 ILCS 460/3, 460/4 and the AG990-IL filing instructions, read 16 September 2026. The Attorney General’s short-form option also requires assets of $25,000 or less. Figures change; check the source.
A review and an audit are different jobs. In a review, the statute defines the CPA’s work as obtaining limited assurance and reporting whether they are aware of any material modifications the statements need. An audit ends in an opinion that the statements fairly represent the organization’s operations. The difference shows up in the engagement, the timeline and the fee.
A complete report also carries the $15 filing fee (required when contributions exceed $15,000 or assets exceed $25,000), the signatures of two officers — the president or another authorized officer, and the chief fiscal officer — and a copy of the federal return the organization filed with the IRS, such as Form 990 or 990-EZ, without Schedule B. The instructions also accept the signatures of two trustees, and one signature if there is only one trustee. If you are not sure which federal return applies, our Form 990 filing requirements guide walks through it.
Small organizations have a shortcut. With gross contributions and assets of $25,000 or less, a soliciting organization may file the AG990-IL disclosing only total revenue, total expenditures and year-end assets, and the $15 fee is due only if contributions were more than $15,000.
If your tier calls for an audit or review, our list of nonprofit audit firms shows CPA firms that work only or mostly with nonprofits. Confirm that the firm you hire can practice in Illinois.
The $25,000 line for paid fundraising
The $25,000 figure is easy to overlook, and it did not move when the other thresholds did. The Attorney General’s notice on the 2024 amendment says the audit threshold for organizations that use a paid professional fundraiser “has not changed.”
Picture how it can arrive. Contributions are around $200,000, raised by staff. The board approves a contract with a firm to run a year-end campaign. Nothing about the finances looks different in the budget. But the organization has moved from the “Staff and volunteers only” column to “Paid fundraising involved,” and the annual report for that year needs an audit rather than a financial statement — a cost nobody put in the campaign budget.
Two sources, two phrasings
The statute describes fundraising “not carried on solely by staff employees or persons who are unpaid for such services.”
The AG990-IL instructions describe a public charity that “raised contributions in excess of $25,000 through the services of professional fund-raiser.”
The two are not worded the same way. Illinois law also separates a professional fund raiser, who conducts or manages a solicitation for pay, from a professional fund raising consultant, who is paid a fixed fee to plan or advise but does not solicit or handle contributions. The professional fund raiser definition also catches a director, officer or employee in a management position whose pay is mostly a percentage of funds raised. If you pay anyone outside your staff for fundraising work and are unsure which line applies, ask the Charitable Trust Bureau before the year closes rather than after the report is due.
Using a professional fund raiser also adds a form. The AG990-IL instructions require a separate Form IFC, Report of Individual Fundraising Campaign, for each campaign, signed by both the fund raiser and an officer or director of the organization.
When the AG990-IL is due, and how to get more time
The report is due within six months after the fiscal year ends — June 30 for an organization on a calendar year.
There are two ways to extend it, and they can be used together:
60-day extension
A written request to the Attorney General before the due date. For compliant organizations, requests received on or before the due date are automatically granted.
Match the IRS extension
If an IRS extension pushes the federal return past the Illinois date, request a matching extension in writing, with a copy of the IRS extension or Form 8868.
Both come with the same condition, stated in the Attorney General’s extension instructions: “An organization must be registered and in good standing to obtain an extension.” Requests go in writing before the original due date, or before an extended one if you already have it.
Missing the date costs more than the fee. If neither a complete report nor a written extension request arrives before the due date, a $100 late report fee applies, and the report will not be accepted without it. Under Section 2, an organization that fails to file a required annual report does not keep its registration; to register again, it files the past reports and pays a $200 re-registration fee, plus the $15 filing fee and $100 late fee for each late report.
Filing online, and why complete matters
The Attorney General launched an online filing system for charitable organizations in August 2025. Its overview slides describe extension requests, electronic signatures sent by email to each signer, and payment online or by mailed check — with a submission voided if a mailed payment has not arrived within 30 days.
The word that runs through every set of instructions is complete. The AG990-IL instructions put it in capitals: “A REPORT WILL NOT BE CONSIDERED FILED UNLESS IT IS COMPLETE.” A report missing a signature, the federal return, or a required audit is not a late-but-filed report. It is not filed. What is filed is also public. The Attorney General’s Charitable database lets anyone check whether a charity is registered and compliant with reporting requirements, and it provides financial information such as assets, income and annual financial reports.
The Attorney General’s 2026 webinar slides show why that matters. In a “Progress So Far” summary that gives some figures as of April 16, 2026, the acceptance rate for online filings was 88.86%; for paper filings it was 76.80%, and the slides name the common issue with paper as incompleteness. The slides do not say why the rates differ. They do say the online system prompts you to upload audited or reviewed financial statements when your answers call for them.
The 2029 date written into the statute
The $500,000 audit line and the $300,000 to $500,000 review tier came from Public Act 103-0121, effective January 1, 2024. The Attorney General’s notice says they apply to annual reports whose initial due date, without extensions, falls after that date.
Section 4 ends with a sentence that is easy to miss: the changes made by that Act “are inoperative on and after January 1, 2029.” Before the amendment, the audit line for organizations raising money with staff and volunteers was $300,000, and there was no reviewed-statement tier.
The statute does not describe what the General Assembly might do before then, and we will not guess. What it does mean is practical: if your organization sits between $300,000 and $500,000 in contributions, check the Illinois statute again before arranging a review or audit for a report prepared around that date. The $25,000 line for paid fundraising was not part of that change.
What to settle before your fiscal year closes
Start with these, and add to them as the organization grows:
- Estimate contributions the Illinois way — including gross event and merchandise income — and see which row of the table you are likely to land in.
- List everyone paid for fundraising work who is not on staff, and note which column may apply. If it is unclear, ask the Charitable Trust Bureau now.
- Book the CPA early if a review or an audit is likely. The report is due six months after year-end, and the engagement has to finish before that date, or the extended date if you requested one in time.
- Put the due date and the extension date on a calendar someone owns — our nonprofit compliance calendar checklist is a starting point.
- Set up the online filing account before the deadline month, including who signs as president and who signs as chief fiscal officer.
If your contributions are well under $25,000 and nobody is paid to raise money, most of this list shrinks to the first item and the last two.
Getting help with the annual report
GivingArc | Nonprofit accounting
Bookkeeping, monthly close, and Form 990 preparation for small nonprofit teams. A review or audit for the AG990-IL still comes from an independent CPA.
To work from the official sources directly, our compliance resource finder lists federal and state pages with the date each was last checked.
Sources reviewed
Every fact above was read on the pages below on 16 September 2026. Thresholds, fees and procedures change; check the source before relying on any figure here.
- 225 ILCS 460/1 — Definitions — contributions, professional fund raiser and consultant, reviewed financial statements.
- 225 ILCS 460/2 — Registration — registering before soliciting, and what happens to registration after a missed report.
- 225 ILCS 460/3 — Exemptions — religious organizations and the $15,000 exemption.
- 225 ILCS 460/4 — Annual reporting for charities — audit and review thresholds, due date, late fee, and the 2029 inoperative date.
- Public Act 103-0121 — the 2024 amendment and the previous $300,000 audit line.
- Attorney General notice of amendment to Section 4 — effective date and the unchanged $25,000 threshold.
- Form AG990-IL filing instructions — what a complete report includes, contributions, Form IFC, simplified filing.
- Charitable organization registration instructions — registration documents and fees.
- Charity annual report extensions — the 60-day and IRS-matching extensions.
- 2026 online filing overview webinar slides — the online system and acceptance rates.
- Illinois Attorney General — Charity Registration — registration and annual report forms.
- Illinois Attorney General — Charitable Giving — the August 2025 online filing launch and the public Charitable database.
Frequently asked questions
Within six months after the organization’s fiscal year ends, which is June 30 for a calendar-year organization. A written request made before the due date can add 60 days, and a separate request can match an IRS extension.
An independent CPA audit is required when contributions exceed $500,000, or when fundraising is not carried on solely by staff and unpaid volunteers and contributions exceed $25,000. Organizations using only staff and volunteers with contributions over $300,000 and up to $500,000 file reviewed financial statements instead.
Yes, in most cases. The AG990-IL instructions define contributions to include gross sums paid by the public for merchandise, special events, rights or services of the organization, in addition to cash donations. One exception: admission ticket sales by a 501(c)(3) music or theater organization that regularly presents live performances are not contributions. Donated services and union member dues are not contributions either.
Yes, in most cases. Registration with the Illinois Attorney General comes before any solicitation. An organization that does not intend to receive, and does not receive, more than $15,000 in contributions in any 12-month period ending December 31 may be exempt from annual reports once the Attorney General confirms the exemption, but it still registers under Section 2 of the Solicitation for Charity Act.
If neither a complete report nor a written extension request arrives before the due date, a $100 late report fee applies and the report is not accepted without it. An organization that fails to file a required report does not keep its registration; to register again it files the past-due reports and pays a $200 re-registration fee, plus the filing and late fees for each late report.
Related NPO Resources guides
- Charitable solicitation registration — what triggers registration, and how states differ.
- Form RRF-1: California charity registration renewal — California’s annual filing, due the same day as a calendar-year 990.
- CHAR500: New York charity annual filing — the New York equivalent, where the registration category sets the due date.
- BCO-10: Pennsylvania charity registration — Pennsylvania’s registration and renewal, where fees and audit levels follow national contributions.
- North Carolina charitable solicitation license — North Carolina’s license, where paying an officer can remove the small-organization exemption.
- New Jersey charity registration — New Jersey’s registration, where the audit line counts only monetary donations.
- Form 990 filing requirements — the federal return your Illinois report has to include.
- Nonprofit compliance calendar checklist — putting state and federal deadlines on one calendar.
- Compliance resource finder — official federal and state sources, each with the date last checked.