How to Complete and Submit Illinois Form CO-1: Filing, Exemptions, and Deadlines

Illinois Form CO-1 is the registration statement a charitable organization files with the Illinois Attorney General’s Charitable Trust Bureau before it solicits donations or spends charitable funds in the state. You file it together with Form CO-2 (the financial information form), the required attachments, and a $15 fee, either through the Bureau’s online portal at charitable.illinoisattorneygeneral.gov or by mail to the Bureau’s Chicago office.¹

Who Has to File

Two Illinois statutes drive the requirement. Under the Solicitation for Charity Act (225 ILCS 460), every charitable organization that solicits or plans to solicit contributions from people in Illinois, or that is located in the state, must file before any solicitation begins. Under the Charitable Trust Act (760 ILCS 55), any trustee holding charitable property worth more than $4,000 during any twelve-month period must register as well.² The obligation covers nonprofit corporations, trusts, and informal groups collecting money for a charitable purpose, whether or not the IRS has yet granted tax-exempt status.³

Common Exemptions

Some organizations do not have to register. Religious corporations, trusts, or organizations holding property for religious, charitable, hospital, or educational purposes are exempt under the Charitable Trust Act, along with agencies directly supervised by such religious entities.³ The Solicitation for Charity Act adds several more categories under 225 ILCS 460/3:⁴

Charities that neither intend to receive nor actually receive more than $15,000 in contributions during any twelve-month period ending December 31. If receipts later exceed $15,000, filing becomes mandatory.
Universities recognized by the State Board of Education or accredited by a regional accrediting association, and their affiliated foundations.
Fraternal, patriotic, social, educational, alumni organizations, and historical societies, when fundraising is confined to their own membership.
People soliciting for the relief of a specific individual named at the time of solicitation.

If your group uses a professional fundraiser to reach the general public, check whether that activity pulls you back out of an exemption you would otherwise qualify for.

When to File

The deadline is tied to what you are about to do, not the calendar. Under the Solicitation for Charity Act, registration must be on file before any solicitation. Under the Charitable Trust Act, a trustee must file before any disbursement of charitable property, or within six months of first receiving property for a charitable purpose, whichever comes first.² File before you start asking for money or spending it.

What to Gather Before You Start

Assembling the packet before you open the form is the difference between a clean filing and a stalled one.

Your Federal Employer Identification Number (FEIN).
A list of every current officer, director, or trustee, with mailing addresses and daytime phone numbers.⁵
Your IRS determination letter if you have one. If your exemption application is pending, attach a copy of IRS Form 1023 or 1024. If you have neither, attach a written explanation.⁵
Formation documents. Corporations attach Articles of Incorporation with all amendments plus bylaws; if incorporated outside Illinois, add a Certificate of Authority from the Illinois Secretary of State. Unincorporated associations attach their constitution, amendments, and bylaws. Charitable trusts attach the Declaration of Trust, all amendments, an inventory, and a recent accounting.⁵
The $15 registration fee, by check or money order payable to the “Illinois Charity Bureau Fund.”¹

Filling Out the Form

At the top, enter the organization’s legal name exactly as it appears on your formation documents, along with its telephone number and FEIN. Then provide the principal mailing address and the state and date of incorporation or formation.⁶

Item 7 asks for the organization’s purposes and the purposes for which contributions will be used. Be specific. “To support after-school literacy programs for children in Cook County” tells the reviewer what you do. “Charitable purposes” does not.

You will also enter your fiscal year end date, which sets the clock for future annual reports. Attach the officer and director list, and check the box that matches your IRS status, attaching the determination letter or Form 1023/1024 as appropriate.⁶

Signatures matter. Two officers of a corporate charitable organization must sign. For non-corporate organizations such as trusts, two trustees sign. If the organization has only one officer or trustee, a single signature is accepted.²

Don’t Forget Form CO-2

An initial registration is not complete without Form CO-2, the Charitable Organization Financial Information Form.² CO-2 covers basic revenue, expense, and asset figures, and it is available on the same Attorney General page as CO-1. Sending CO-1 alone is an incomplete filing.

How to Submit

Online

The Charitable Trust Online Filing System at charitable.illinoisattorneygeneral.gov lets you complete the forms, upload attachments, and pay the fee electronically. You can save drafts and track the status of what you have submitted. Online filings receive priority processing over paper.⁷

By Mail

Send the completed CO-1, CO-2, all attachments, and your $15 check or money order to:

Office of the Illinois Attorney General
Charitable Trust Bureau
100 West Randolph Street, 11th Floor
Chicago, Illinois 60601-3175⁵

Use a mail service with tracking. The Bureau reviews filings in the order received, and there is no acknowledgment until a staff member opens the packet. Once processed, you receive a CO registration number that identifies your organization in every future filing.

After You’re Registered

Registration is not a one-time step. Every registered organization files Form AG990-IL, the Illinois Charitable Organization Annual Report, each year to stay in good standing. It is due within six months of the close of your fiscal year, so a calendar-year organization files by June 30, and the fee is $15.⁸ A full filing includes the AG990-IL, your IRS return such as Form 990, audited financial statements if applicable, and any other attachments the form calls for. Organizations with more than $25,000 in revenue or assets during the fiscal year file the full report; those below both thresholds file a simplified summary.⁹

If you cannot meet the deadline, send a written extension request to the Bureau before the due date with the organization’s name, CO number, and FEIN. That gets you sixty extra days. If you need more time after that, you can request a further extension of up to two and a half months by submitting a draft AG990-IL with preliminary figures, financial statements, all required fees, and a copy of any IRS extension. You must be registered and in good standing to qualify.¹⁰

Miss the deadline without an extension and a $100 late filing fee applies automatically. The report is not treated as filed until that late fee is paid.⁸

What Happens If You Don’t Register

The Attorney General can go to circuit court and get an injunction stopping an unregistered organization from soliciting or collecting funds. A court can also order the removal of officers, an accounting of funds, and other equitable relief. On top of that, the court can impose a civil penalty of between $500 and $1,000 on an organization or trust estate that failed to register or maintain its registration.¹¹

If your registration lapsed or you never filed at all, catching up is expensive. Late or re-registration filings must include a current registration statement, financial reports for every past year the organization should have been registered, and a $200 penalty registration fee instead of the usual $15.¹¹ Filing before you solicit costs less and keeps your fundraising authority intact.

1
Office of the Illinois Attorney General. Charity Registration
2
Legal Information Institute. Illinois Administrative Code tit. 14, 480.30 – Registration
3
Illinois Attorney General. Illinois Charitable Organization Laws
4
Illinois General Assembly. Illinois Code 225 ILCS 460/3 – Exemptions
5
Illinois Attorney General. Illinois Form CO-1 Charitable Organization Registration
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Illinois Attorney General. Form CO-1 Charitable Organization Registration Statement
7
Office of the Illinois Attorney General. Charitable Trust Online Filing System
8
Office of the Illinois Attorney General. Form AG990-IL Filing Instructions
9
Illinois General Assembly. Illinois Code 760 ILCS 55/7 – Reports by Trustees
10
Illinois Attorney General. Charity Annual Report Extensions
11
Illinois General Assembly. Illinois Compiled Statutes – Solicitation for Charity Act