Illinois Nonprofit Compliance Guide: Formation, Charity Registration, Taxes, Gaming, and Reporting

What the Illinois guide covers

The Illinois guide (/states/illinois/) documents the ordinary nonprofit lifecycle under 805 ILCS 105: not-for-profit corporate formation, governance, the Secretary of State annual report, foreign qualification, Attorney General charity registration under two separate statutes, AG990-IL annual charity reporting, post-2024 financial-review and audit thresholds, professional fundraising, state taxation, property-tax exemption, employment, charitable gaming, alcohol special-event licensing, activity-specific licensing, lobbying and political activity, and dissolution with charitable-asset oversight.

It is built from 77 individually sourced facts citing 93 official Illinois sources — the Illinois General Assembly's own statute compilation, Secretary of State Department of Business Services forms and instructions, the Attorney General's Charitable Trust Bureau, the Department of Revenue, the Department of Employment Security, the Illinois Liquor Control Commission, and other official state and local sources.

Formation uses "not-for-profit," not "nonprofit," terminology

Illinois's ordinary corporate statute and forms officially use the term "not-for-profit corporation," governed by the General Not For Profit Corporation Act of 1986 (805 ILCS 105). A domestic filing uses Form NFP 102.10, carries a $50 standard fee plus an optional $25 expedited fee, and requires at least three initial directors and an eligible incorporator. The corporation must continuously maintain an Illinois registered agent and a physical registered office.

Illinois also has a separate Religious Corporation Act (805 ILCS 110) that a religious organization should consider before choosing a statutory form — current official guidance does not fully resolve when a modern religious organization should choose it over 805 ILCS 105, so this guide holds that choice Verification in Progress rather than recommending one path.

Two separate annual reports: NFP 114.05 and AG990-IL

The Secretary of State annual report (Form NFP 114.05) is due before the first day of the corporation's anniversary month each year, not merely sometime during that month. The state filing fee is $10, with a $3 statutory late fee; a domestic corporation may file electronically when eligible, but current Secretary of State instructions state that a foreign not-for-profit corporation may not file this report electronically and must use the accepted paper method instead.

The Attorney General's AG990-IL charitable annual report is a completely different filing, generally due six months after the organization's fiscal-year end (for a calendar-year filer, that is June 30). It requires attaching the applicable federal return or report and financial statements, and Illinois offers a 60-day extension on request — a federal extension does not automatically extend the Illinois deadline. AG990-IL signature rules are specific rather than universal: a corporate filer ordinarily needs two different officers (the president or another authorized officer, plus the chief fiscal officer), while a noncorporate trust ordinarily uses two trustees but may submit one signature when it has only one trustee.

Two charity statutes with different triggers

Illinois charity compliance runs through two separate statutes that are easy to conflate. The Charitable Trust Act applies to a covered trustee holding charitable property with a fair-market value greater than $4,000 during any 12-month period, with registration due before the first disbursement or within six months after the property is received, whichever occurs first. The Solicitation for Charity Act separately applies to an organization soliciting contributions in Illinois, with registration due before solicitation begins.

An organization can be subject to only the Charitable Trust Act, only the Solicitation for Charity Act, or both at once — they are evaluated independently, using Form CO-1 (and CO-2 where applicable) for registration under either. Illinois also keeps two separate religious-exemption systems: the Solicitation for Charity Act's CO-3 determination process (an Attorney General exemption request, not an automatic exemption) and the Charitable Trust Act's own exemption for exclusively religious activities of qualifying organizations and their supervised affiliates. Qualifying under one system does not automatically resolve the other.

Post-2024 review and audit thresholds

Without a paid professional fundraiser, Illinois currently requires reviewed financial statements when gross contributions are more than $300,000 through $500,000, and audited financial statements above $500,000. When a paid professional fundraiser is used, audited financial statements are required once gross contributions raised through that context exceed $25,000. These are the current post-2024 thresholds, and the guide preserves their exact comparison operators rather than the earlier pre-2024 figures.

Separate, lower-dollar thresholds govern simplified reporting and the $15 annual charity filing fee under each statute — the Solicitation for Charity Act measures gross contributions and assets, while the Charitable Trust Act-only formula measures gross revenue and assets. The guide keeps these two fee formulas distinct rather than merging "gross contributions" and "gross revenue."

Federal recognition does not create Illinois tax exemptions automatically

Federal 501(c)(3) recognition and Illinois incorporation do not by themselves create an Illinois sales-tax exemption, an Illinois E-number, or a real-property-tax exemption. Sales-tax-exempt purchasing requires a separate E-number application, and that E-number expires on its own five-year cycle and must be renewed. Real-property-tax exemption is administered through the county board of review or assessor together with Department of Revenue review using the PTAX-300 framework — county-specific deadlines, affidavits, and renewal procedures vary, and the guide does not present any single county's practice as a statewide rule.

Gaming systems are kept separate

Raffles and poker runs are licensed locally under the Raffles and Poker Runs Act, subject to a local enabling ordinance, county or municipal licensing, and locally set prize, ticket-price, and sales-period limits. Bingo, charitable games, and pull tabs and jar games are separate Department of Revenue licensing systems with their own eligibility, event limits, and tax-reporting rules. A raffle license does not authorize casino-style charitable games, and a charitable-games license does not authorize raffle ticket sales — each system stays on its own track.

What remains under verification

11 of the guide's 77 facts are currently labeled Verification in Progress, including: whether and when a religious organization should use the separate Religious Corporation Act; whether Illinois has an unconfirmed post-formation initial-report or publication duty; internet and crowdfunding solicitation nexus; county-by-county property-tax exemption deadlines and affidavits; whether Illinois has any single universal business license; the exact unemployment-financing election security mechanics; program-specific worker classification; online and electronic raffle-ticket sales; the February 2026 ILCC Portal transition's reconciliation with legacy special-event liquor guidance; Illinois political-committee registration's interaction with federal 501(c)(3) restrictions; and Attorney General/court review of restricted charitable assets in dissolution.

Every other fact in the guide — including the not-for-profit entity type, the NFP 114.05 and AG990-IL deadlines, the Charitable Trust Act and Solicitation for Charity Act triggers, the post-2024 review and audit thresholds, and the core gaming and dissolution filing sequence — is source-verified against current official Illinois materials. The guide keeps every Verification in Progress item visibly labeled rather than resolving it by assumption.