990 Filing Law Will Take Effect December 13, 2014 for Charitable Organizations in PA

This update is applicable to all 501 (c)(3) organizations that need to file with the Bureau of Charitable Organizations (BCO). As was discussed in a previous BSSF blog post, Governor Corbett signed into law Act 141 of 2014 on October 14, 2014. This Act changes the renewal date for charitable organizations from 135 days after the close of the fiscal year to the 15th day of the fifth month following the close of the fiscal year. The Act also allows the Bureau of Charitable Organizations to extend the time for filing the renewal of an organization’s registration to a date not to exceed the 15th day of the eleventh month following the close of the organization’s fiscal year.

The law takes effect on December 13, 2014. In order to determine when this change is effective for your organization you must look at when the due date would be for your most recent renewal andnot your fiscal year-end date. If your fiscal year ended January 31, 2014, the due date (with maximum extensions) prior to the change in the law, would have been December 12, 2014. Since the law becomes effective December 13, 2014, this due date remains unchanged. However, for fiscal years ending on or after February 28, 2014, the BCO renewal deadline now corresponds to the IRS 990 deadline (15th day of the fifth month after your fiscal year-end).

It is helpful to visualize the fiscal year-end dates and the corresponding due dates assuming maximum extension requests have been filed with the IRS for your 990. Here is how the 2014 fiscal year ends and corresponding BCO renewal deadlines look:

Fiscal Year-end Maximum Due Date
January 31, 2014 December 12, 2014
February 28, 2014 January 15, 2015
March 31, 2014 February 15, 2015
April 30, 2014 March 15, 2015
May 31, 2014 April 15, 2015
June 30, 2014 May 15, 2015
July 31, 2014 June 15, 2015
August 31, 2014 July 15, 2015
September 30, 2014 August 15, 2015
October 31, 2014 September 15, 2015
November 30, 2014 October 15, 2015
December 31, 2014 November 15, 2015

These due dates as well as more information on the law can be found on the Bureau of Charitable Organizations website. Our Not-for-Profit Team is also available as a resource for your organization as you navigate through your filing requirements and deadlines.