New Hampshire Nonprofit Reporting: The Five-Year Corporate Report vs. the Annual Charitable Trust Report

Direct answer: which report is due, and when

A New Hampshire nonprofit corporation that is also a registered charitable trust has two recurring reports. The Chapter 292 nonprofit report goes to the Secretary of State in years ending in 0 or 5, by December 31, and costs $25. Form NHCT-12 goes to the Department of Justice Charitable Trusts Unit every year, four months and fifteen days after the close of the fiscal year, and costs $75.

So in an ordinary year the answer is that only the charitable-trust report is due. In 2030, and again in 2035, both are due, and they are still two separate filings to two separate agencies with two separate fees.

The confusion is understandable, because most states put a single annual or biennial report at the Secretary of State and give the charity regulator something that looks like a renewal. New Hampshire does neither. Its corporate report is on a five year cycle, and its charity report is a charitable-trust report rather than a registration renewal.

The five-year corporate report, in detail

RSA 292:25 sets the cycle. The report is filed in years ending in 0 or 5, by December 31. It states the principal business address and the names and addresses of the officers, directors or governing-board members, and it is signed by the president or another officer. The fee is $25.

Two consequences of that wording are worth spelling out. First, the next ordinary statutory reporting year after 2025 is 2030, so an organization formed in 2026 will ordinarily have its first corporate report fall due on December 31, 2030 rather than in its first year. Second, the content is corporate rather than financial, which is why filing a federal return can never stand in for it.

Use the Secretary of State filing channel that is current at the time you file. The legal duty is settled, but the guide deliberately does not hard-code today’s online screens for a filing that is years away, and the state guide carries that channel question as VERIFICATION IN PROGRESS for exactly that reason.

What happens if the corporate report is missed

Nonfiling is not a fee-and-forget situation. Failure to file can lead to revocation or annulment of the charter, which means the corporation loses the standing that every contract, lease, grant agreement and bank account depends on.

Getting it back is its own procedure. The statutory revival path applies, and it carries a $50 revival fee plus the arrears owed. Plan the December 31 date of a reporting year like a deadline that can cost the entity, not like a routine confirmation.

The annual charitable-trust report, in detail

Form NHCT-12 is the annual or periodic charitable-trust report to the Charitable Trusts Unit. The recurring statutory deadline is four months and fifteen days after the close of the fiscal year, with the first report tied to the first applicable fiscal or calendar year, and the fee is $75.

Work the deadline from your own year end rather than from a fixed calendar date. A December 31 year end puts the report due on May 15. A June 30 year end puts it on November 15. A September 30 year end puts it on February 15. The formula is the rule, and the date follows from it.

There is a relief valve, but it has to be obtained. A charity may seek a written suspension or exemption from periodic reporting where the Attorney General makes the statutory finding. Until that written decision exists, the ordinary annual duty continues.

What happens if the charitable-trust reports are missed

One late report is a problem to fix. Two successive years of failing to file required reports is treated as a statutory breach, which changes the character of the situation from an administrative lapse to a compliance failure by the trustees.

The practical consequence is that a charity catching up should not treat the older missing year as expired history. Both years remain part of the record the Charitable Trusts Unit is looking at.

The two financial thresholds that sit above the annual report

The annual report is where two separate financial obligations attach, and they are not one sliding rule. At $500,000 or more of covered revenue, gains and support, the current RSA 7:28 requirement is the latest GAAP financial statement, under the statutory conditions.

At $2,000,000 or more of covered revenue, gains and support, the requirement is audited GAAP financial statements, subject to the statutory relief provisions. A charity at $600,000 owes the financial statement and not the audit. A charity at $2,100,000 is in the audit branch.

Both figures are stated as at-or-above thresholds, so a charity landing exactly on $500,000 or exactly on $2,000,000 is inside the branch rather than under it. Neither threshold has anything to do with the corporate report.

A checklist for telling them apart

Ask which agency. Secretary of State means the corporate report. Department of Justice, Charitable Trusts Unit means NHCT-12.

Ask what the year ends in. If the calendar year ends in 0 or 5, a corporate report is due by December 31 of that year. If not, no corporate report is due this year.

Ask when your fiscal year closed. Add four months and fifteen days, and that is the NHCT-12 date, every year, regardless of what the corporate cycle is doing.

Ask what the fee is. $25 is the corporate report. $75 is NHCT-12. If a checklist shows one annual filing with one fee, it is not describing New Hampshire.

Ask what your revenue was. If covered revenue, gains and support reached $500,000, add the GAAP financial statement to the annual report. If it reached $2,000,000, the audit branch applies instead.

The complete New Hampshire guide, including registration, the pecuniary-benefit rules, taxes, employment, gaming and closure, is at https://501c3.help/states/new-hampshire/ and the launch overview is at https://501c3.help/updates/new-hampshire-nonprofit-compliance/