How to Complete and Submit Maryland Form COF-85: Parts, Deadlines, and Fees

Maryland Form COF-85 is the Annual Financial Report for Charities, a two-page substitute for the IRS Form 990 that charitable organizations file with the Secretary of State as part of their registration or yearly renewal. You complete it only if your organization files the 990-N e-Postcard with the IRS or files nothing with the IRS at all. If you file a full 990 or 990-EZ, you skip the COF-85 and submit a signed copy of that return instead.¹

Who Has to File It

Maryland Code, Business Regulation § 6-401 requires every charitable organization to register with the Secretary of State before soliciting contributions in the state, before having anyone solicit on its behalf, or before soliciting from outside Maryland if the organization is based here. Registration includes a financial report for the most recently completed fiscal year.²

Which form satisfies that report depends on what you file federally. Full 990 or 990-EZ filers attach a signed copy of the federal return and are done. Everyone else, meaning 990-N filers and organizations exempt from IRS filing, completes the COF-85.¹

Two financial thresholds change what has to go in the packet alongside the COF-85. Organizations with charitable contributions of at least $300,000 but under $750,000 must include a financial review by an independent CPA. At $750,000 or more, a full independent audit is required.³

What to Pull Together Before You Start

The form moves fastest when the underlying records are in front of you. Gather:

Your federal Employer Identification Number.
The exact start and end dates of the fiscal year you are reporting.
Bookkeeping or treasurer’s records covering ten revenue categories and four expense categories.
Names, addresses, titles, average weekly hours, and reportable compensation for every officer, director, trustee, and key employee.
A plain-language description of each program your organization ran during the year, with the expenses tied to it.

The COF-85 travels with a larger packet. For an initial registration you file Form COR-92; for a renewal you file the Annual Update of Registration. Either way, the packet also typically includes your IRS tax determination letter, articles of incorporation, bylaws, a current board list, and any contracts with professional solicitors or fundraising counsel.⁴

Working Through the Six Parts

At the top of page one, enter your organization’s legal name, mailing address, EIN, and the fiscal year end you are reporting on. The body of the form is divided into six parts.¹

Part I: Statement of Revenue

Lines 1 through 10 cover every source of money the organization received. Line 1 is contributions and donations. Line 2 is government grants and monies. Line 3 is program service revenue. Line 4 is membership dues and assessments. Line 5 is investment income. Line 9 is other income, with an explanation attached. Line 10 is the total of lines 1 through 9.

Lines 6, 7, and 8 trip people up most often because each has three sub-lines. Fundraising and special events (6a–6c), gaming (7a–7c), and sales of inventory (8a–8c) all use the same structure: gross revenue on the “a” line, direct expenses or cost of goods sold on the “b” line, net on the “c” line. Don’t collapse these into a single net figure. The state wants both sides of the math.

Part II: Statement of Expenses

Lines 11 through 15 sort spending into program services, management and general, fundraising, and other. If anything lands on Line 14 (other), attach a written explanation. Line 15 totals the four categories.

Part III: Totals

Line 16 subtracts total expenses from total revenue. Line 17 is net assets at the start of the fiscal year. Line 18 adds the two to give net assets at year end. A deficit on Line 16 is reported as a negative number; the form simply needs an accurate figure.

Part IV: Statement of Program Accomplishments

Describe what the organization actually did during the year and the expenses allocated to each program. There is no required format. Plain language, identifying each program and its cost, is enough.

Part V: Officers, Directors, Trustees, and Key Employees

List every person in a leadership role, together with principal salaried staff and anyone with final responsibility over handling or distributing charitable contributions. For each, give name, address, title, average hours worked per week, and reportable compensation. The address can be the organization’s physical address.⁴

Part VI: Other Information

Line 19 asks whether the organization is related, through common board members, trustees, or officers, to any other charitable or non-charitable organization. Line 20 asks for the name, location, phone, and email of whoever maintains the books. An outside bookkeeper or accountant goes here.

Sign the form before sending it.

Where to Send It, What It Costs, How Long It Takes

Mail the signed COF-85 with the COR-92 or Annual Update of Registration, all supporting documents, and the fee to:

Charitable Organization Division
Office of the Secretary of State
16 Francis Street
Annapolis, MD 21401

Email submissions go to dlcharity_sos@maryland.gov.¹

Registration fees run from $50 to $300, scaled to the organization’s contribution level. Checks and money orders are payable to the Secretary of State.⁵

Paper filings usually take 30 to 60 days to process. The Maryland OneStop online portal can bring that down to 10 to 30 days. Expect longer waits in May, June, November, and December.⁴

Renewal Deadline and the Automatic Extension

After the first registration, the organization renews every year, filing a new COF-85 if its IRS filing situation still calls for one. The annual packet is due within 10.5 months after the fiscal year ends. For a December 31 year-end, that falls in mid-November.

If you have a current registration and have not filed by six months after your fiscal year ends, the Secretary of State automatically grants an extension to the 15th day of the 11th month after fiscal year close. No IRS Form 8868, no separate state extension request. The extension covers the whole annual update, not just the federal return.⁴

Miss even the extended date and a late fee of $25 for each month or partial month accrues on top of the registration fee.⁶

Don’t Forget Solicitor Contracts

If your organization uses a professional solicitor or fundraising counsel, copies of every active contract have to go in with both the initial and annual filings. Amendments count too, unless you already submitted them separately. If the solicitor subcontracts any duties, the subcontract comes in as well.⁷

Forgetting to attach these is one of the most common reasons packets come back. Organizations that handle all fundraising in-house can skip this step.

If Your Organization May Be Exempt

Not every nonprofit files the full COR-92 and COF-85 packet. Organizations that receive less than $25,000 in charitable contributions can file the Exempt Organization Fund-Raising Notice instead. Religious organizations and membership-based groups may also qualify for exemption, but they have to request it in writing from the Secretary of State and include supporting documents such as bylaws, articles of incorporation, and the IRS tax determination letter.⁶

Exemption is not automatic. Something still has to be filed. What changes is the scope of the filing and how much financial detail the state requires.

1
Maryland Secretary of State. Maryland Instructions for Annual Financial Report for Charities – Form COF-85
2
Maryland General Assembly. Maryland Code Business Regulation 6-401 – Registration of Charitable Organizations
3
Maryland General Assembly. Maryland Code Business Regulation 6-402
4
Maryland Secretary of State. Instructions for Completing Annual Update of Registration
5
Maryland OneStop. SOS Charities Initial Registration Form
6
Maryland Secretary of State. Registering a Charity
7
Maryland Secretary of State. Professional Solicitor or Fund-raising Counsel