Pennsylvania Form BCO-23 is the Public Disclosure Statement that charities file when their federal return is a 990-N, 990-EZ, or 990-PF, or when they’re covered by a parent organization’s 990 group return. It goes in the same envelope as your BCO-10 Charitable Organization Registration Statement, along with a copy of whatever IRS return you did file. The deadline is the 15th day of the fifth month after your fiscal year ends, and the Bureau of Corporations and Charitable Organizations accepts it only by mail.
Who Has to File BCO-23
BCO-23 is not a standalone registration. Every charity soliciting contributions from Pennsylvania residents registers on the BCO-10; BCO-23 is an extra disclosure required when the IRS return you submit with that registration isn’t a full 990.
You need BCO-23 if your organization files any of the following with the IRS:
- Form 990-N (the e-Postcard for small organizations)
- Form 990-EZ
- Form 990-PF (private foundations)
- A parent organization’s 990 group return that covers you as an affiliate
Charities that file a full Form 990 don’t use BCO-23. The 990 itself provides the disclosure the Bureau is looking for.
What to Have on Hand Before You Start
Pull these together before you open the form:
- Your organization’s legal name and the certificate number assigned by the Bureau when your initial BCO-10 was approved
- Federal Employer Identification Number
- Fiscal year end date, which drives both the reporting period and the due date
- A copy of your most recent IRS filing (990-N confirmation, 990-EZ, 990-PF, or the parent’s group 990)
- Financial statements at whatever level your contribution total requires
- Names and contact information for all officers, directors, trustees, and your principal executive
If you use a professional solicitor or fundraising counsel, you’ll also need their names, addresses, and copies of any written contracts.
Filling Out the Form
The header collects your organization’s name, certificate number, and fiscal year end date. The body asks for the financial and operational information that would otherwise sit on a full 990: revenue, expenses, officer compensation, and a description of your charitable purpose.
Two authorized officers must sign, and one of them has to be your chief fiscal officer. Those signatures certify the accuracy of everything in the filing under Pennsylvania’s unsworn falsification statute, which works like a penalty-of-perjury declaration.
Fill in every field. Blank fields are the single most common reason the Bureau sends filings back. If a question genuinely doesn’t apply, write “N/A” rather than leaving the space empty.
Financial Statements Required by Contribution Level
Pennsylvania scales the required accounting work to your gross annual contributions:
- $25,000 or less: no separate financial statement beyond the form itself
- $25,001 to less than $100,000: internal financial statements are acceptable
- $100,000 to less than $250,000: statements compiled, reviewed, or audited by an independent licensed public accountant or CPA
- $250,000 to less than $750,000: a review or audit by an independent licensed public accountant or CPA
- $750,000 or more: a full audit by an independent licensed public accountant or CPA
If your contributions are close to a threshold, line up an accountant well before the deadline. A review or audit takes time to arrange and complete.
Registration Fee
BCO-23 itself has no separate fee. The registration fee is paid with the BCO-10 and scales with gross annual contributions:
- $25,000 or less: $15
- $25,001 to less than $100,000: $100
- $100,000 to less than $500,000: $150
- Greater than $500,000: $250
Deadline
Your BCO-23 and BCO-10 must be postmarked by the 15th day of the fifth month after your fiscal year ends. A calendar-year organization files by May 15. A June 30 fiscal year ends up with a November 15 deadline.
The Bureau no longer requires formal extension requests, but your filing still has to arrive on time to keep your registration active. Soliciting contributions from Pennsylvania residents without a current registration violates the Solicitation of Funds for Charitable Purposes Act.
How to Submit It
BCO-23 is mail-only. The Bureau’s online filing system currently accepts the BCO-10, BCO-2, and IPP forms; BCO-23 is not among them. Download the blank form from the Department of State’s registration forms page, print it, complete it, and mail it with your IRS return copy and any required financial statements to the Bureau of Corporations and Charitable Organizations in Harrisburg.
Keep copies of everything you send, and hold onto proof of the mailing date. The postmark is what the Bureau uses to judge whether you met the deadline.
What Happens If You Don’t File
The Solicitation of Funds for Charitable Purposes Act gives the Bureau authority to act against organizations that solicit without a valid registration. It can issue cease-and-desist orders directing you to stop fundraising, and it can impose administrative fines of up to $1,000 per violation. Those fines add up when the Bureau treats each day of noncompliance or each separate solicitation as its own violation.