Pennsylvania charitable-solicitation registration (BCO-10) and the Institutions of Purely Public Charity (IPPC) annual statement are two different compliance systems that happen to be administered by the same Bureau. This explainer walks through what each one covers, when BCO-10 satisfies the IPPC duty, and when an organization can owe IPPC even after a solicitation exemption.
Most Pennsylvania nonprofits that register and renew on BCO-10 never need to file anything separately for IPPC — the BCO-10 filing satisfies the Bureau's annual filing requirement for an organization that is already required to file it, and the current IPPC form itself instructs filers not to submit both for the same period. The separate IPPC statement matters for a narrower group: organizations claiming a Pennsylvania sales-tax or real-property-tax exemption, including some organizations that are exempt from BCO-10 solicitation registration altogether.
BCO-10 is Pennsylvania's charitable-organization registration statement, filed with the Bureau of Corporations and Charitable Organizations. Initial registration is generally required before a compensated person solicits contributions on the organization's behalf, or within 30 days after the organization crosses a $25,000 gross-national-contributions threshold without using a compensated solicitor. Once registered, the organization renews BCO-10 annually, generally postmarked no later than the 15th day of the 11th month after the close of its fiscal year, attaching the required federal return, financial statements, and disclosures.
The Institutions of Purely Public Charity (IPPC) annual statement is a separate filing created by Act 55 of 1997, tied to Pennsylvania's constitutional "purely public charity" concept rather than to charitable solicitation. An organization claiming a Pennsylvania sales-tax exemption or a real-property-tax exemption generally files the IPPC statement together with the organization's federal return, unless a specific exception applies. This is a distinct compliance track from BCO-10 — an organization can owe one, both together (satisfied by the single BCO-10 filing), or neither, depending on its own solicitation activity and tax-exemption claims.
For an organization already required to file BCO-10, that filing takes the place of a separate IPPC statement for the same annual period — the current IPPC form itself states not to file both. This is a narrow, specific rule: it applies to an organization that is filing BCO-10 for that period, not to every organization that happens to also be tax-exempt or file a federal return.
A common point of confusion is assuming that qualifying for a BCO-10 solicitation-registration exemption also excuses an organization from the IPPC statement. It does not — the two exemptions are evaluated on their own separate terms. An organization that is exempt from charitable-solicitation registration but still claims a Pennsylvania sales-tax or property-tax exemption can still owe the separate IPPC statement, unless it independently qualifies for one of the Bureau's specific IPPC exceptions.
The Bureau recognizes two such IPPC exceptions: a bona fide religious institution or integral agency of one that is not required to file federal Form 990, and an organization with gross annual contributions under $25,000 and program-service revenue under $5,000,000. Both conditions in the second exception must be tested for the fiscal year in question — an organization cannot assume a prior year's exception still applies without checking again.
When the separate IPPC statement is required, it is generally due within 135 days after the close of the organization's fiscal year, with a $15 filing fee. An organization that instead satisfies the requirement through BCO-10 pays the applicable BCO-10 fee and does not add a separate $15 IPPC fee on top of it.
Filing IPPC (or satisfying it through BCO-10) is a reporting duty, not the exemption application itself — it is separate from actually obtaining Pennsylvania sales-tax exemption (generally through REV-72 or myPATH) or a local real-property-tax exemption (administered by the county or city assessing authority). Federal 501(c)(3) recognition is relevant supporting evidence for a Pennsylvania exemption claim, but it does not by itself authorize Pennsylvania sales-tax-exempt purchases and does not by itself establish Pennsylvania's constitutional "purely public charity" status, which generally requires satisfying the constitutional test before Act 55 criteria are even considered.
BCO-10: charitable-solicitation registration and renewal; triggered by soliciting contributions (subject to registration exemptions); renewal generally due the 15th day of the 11th month after fiscal year end; satisfies the IPPC duty for the same period when the organization is already required to file it.
IPPC statement: purely-public-charity annual statement under Act 55; triggered by claiming a Pennsylvania sales-tax or property-tax exemption (unless a religious/integral-agency or small-organization exception applies); generally due within 135 days after fiscal year end; $15 fee when it applies on its own, not added on top of BCO-10.
Is the organization already required to file BCO-10 for this period? If yes, file BCO-10 and do not file a separate IPPC statement for the same period.
Is the organization exempt from BCO-10 but still claiming a Pennsylvania sales-tax or property-tax exemption? Check the IPPC religious/integral-agency and small-organization exceptions before assuming no separate filing is owed.
Does the organization qualify for an IPPC exception this fiscal year specifically — not merely in a prior year? Retest gross annual contributions and program-service revenue each year.
Is the organization treating federal 501(c)(3) recognition as if it were Pennsylvania tax exemption? It is not — sales-tax and property-tax exemption each require their own separate Pennsylvania application or process.
6 official sources back this article.
| Agency / Authority | Source | Accessed | URL |
|---|---|---|---|
| Pennsylvania Department of State, Bureau of Corporations and Charitable Organizations | Charitable Organizations | https://www.pa.gov/agencies/dos/programs/charities/information-for-charities/-charitable-organizations | |
| Pennsylvania Department of State, Bureau of Corporations and Charitable Organizations | Purely Public Charities | https://www.pa.gov/agencies/dos/programs/charities/information-for-charities/purely-public-charities | |
| Pennsylvania Department of State, Bureau of Corporations and Charitable Organizations | Institutions of Purely Public Charity Registration Statement | https://www.pa.gov/content/dam/copapwp-pagov/en/dos/programs/charities/purely-public-form.pdf | |
| Pennsylvania General Assembly | Institutions of Purely Public Charity Act, Act 55 of 1997 | https://www.legis.state.pa.us/WU01/LI/LI/US/HTM/1997/0/0055..HTM | |
| Pennsylvania Department of Revenue | Apply for Non-Profit Sales Tax Exemption | https://www.pa.gov/services/revenue/apply-for-non--profit-sales-tax-exemption | |
| Pennsylvania General Assembly | Pennsylvania Constitution, Article VIII, Section 2 | https://www.legis.state.pa.us/WU01/LI/LI/CT/HTM/00/00.008..HTM |
This article explains one part of a larger, continuously-verified state guide. For every fact, deadline, fee, and citation — including anything still marked Verification in Progress — see the full guide.
This article is compiled from official state statutes, agency instructions, forms, and government guidance already documented in the linked state compliance guide(s). It provides general information and does not replace legal, tax, or accounting advice. Where a cited fact is still marked Verification in Progress, treat the underlying point as unresolved and confirm directly with the relevant agency before relying on it.
Written by 501c3.help Research Team. See how 501c3.help verifies state nonprofit compliance requirements for the full research and validation process.