How to File Massachusetts Form PC: Deadlines, Fees, and Schedules

Massachusetts Form PC is the annual financial report every registered public charity files with the Attorney General’s Non-Profit Organizations/Public Charities Division, due four and a half months after your fiscal year ends and submitted exclusively through the AGO’s online Charity Portal.¹ Paper filings are no longer accepted. What follows is a working walkthrough: who files, what to prepare, how to complete each part, and how to pay the correct fee.

Who Has to File

Under Massachusetts General Law Chapter 12, Section 8F, the governing board of every public charity must file an annual report with the division.² The obligation reaches both Massachusetts-based nonprofits and out-of-state organizations that solicit charitable contributions within the Commonwealth.¹

Two categories of charitable organizations are exempt from registering and filing with the AGO: the Red Cross and certain veterans organizations, and certain religious organizations.³ If you think your organization qualifies for a religious waiver, the AGO’s regulations on the subject provide enough detail to make that determination without contacting the division.

When It’s Due and How to Extend

Form PC is due four and a half months after your fiscal year ends. A calendar-year charity closing on December 31 has a May 15 deadline. A six-month extension is available if your organization is in compliance with its other filing obligations.¹

The federal Form 990 runs on the same clock: it is also due the 15th day of the 5th month after the tax year closes, and the IRS grants an automatic six-month extension when you file Form 8868 before the original deadline.⁴ Because Form PC requires your completed federal return as an attachment, most charities that need extra time will request extensions from both agencies.

What to Pull Together Before You Start

A missing attachment is one of the easier ways to stall a filing. Gather the following before you log in to the portal.

A complete copy of your federal Form 990, 990-EZ, or 990-PF for the same fiscal year, with every schedule and attachment.⁵
Audited or reviewed financial statements, if your revenue level requires them.
A current list of officers, directors, and trustees with addresses.
Compensation data for the five highest-paid employees, plus detailed compensation for the chief executive and four other top-paid individuals across related organizations.
Names and addresses of any professional solicitors, professional fundraising counsel, or commercial co-venturers.
Amended bylaws or articles of organization, if changed during the reporting period.

Do You Need an Audit or a Review?

Massachusetts scales the level of outside financial oversight to gross support and revenue for the year, a figure that excludes gains or losses from selling capital assets.²

Over $1,000,000: financial statements audited by an independent CPA, prepared under GAAP and audited under generally accepted auditing standards.
$500,001 to $1,000,000: an audit is technically required, but a CPA review report may be substituted. The review must follow GAAP or another comprehensive basis of accounting.
$500,000 or less: no audit or review is required, though the financial data on the form itself still has to be accurate.

These thresholds come from M.G.L. c. 12, § 8F and are reflected in the AGO’s audit guidance.⁶ If you’re anywhere near either threshold, confirm your gross support and revenue figure carefully before commissioning the engagement. Miscalculating means either paying for an audit you didn’t need or filing without one you did.

Filling In the Form

Most of Form PC is a transfer job: totals from your federal return and internal ledgers move into the state’s format. The financial fields ask for total revenue, total expenses, and net assets, with a breakdown of program services versus management and general. The division uses that split to gauge whether the charity is directing resources toward its stated mission, so the numbers must match your 990 exactly.

Compensation

Question 6 asks for total compensation of your five highest-paid employees, split into salary and other income, benefit plans, and other compensation.⁷ Question 7 asks whether any compensation to those individuals was left out of the table; if so, explain on a separate sheet.

Schedule RO goes further, requiring detailed compensation data for the chief executive and the four other highest-paid current or former directors, trustees, officers, or employees across your system of related organizations. If your charity paid or became obligated to pay compensation to a related party (Question 24H), attach a schedule with the related party’s name and address, the nature of the transaction, the amounts involved, and the process the board used to authorize it.⁷

Related-Party Transactions

Question 24 sweeps in several categories of insider dealings beyond compensation: sales, exchanges, or leases of property with a related party; loans in either direction; and other transfers of value. Each “yes” triggers a supplemental disclosure with the details above. These questions mirror the federal Schedule L (Form 990), which covers loans, grants, and business transactions involving disqualified persons and other interested parties.⁸ If you already completed Schedule L federally, most of the underlying information is in hand.

Schedules A-1 and A-2

If your organization solicited contributions during the fiscal year (Question 13) or plans to solicit during the following year (Question 14), complete Schedule A-1, Schedule A-2, or both.⁷ A-1 reports the year being filed; A-2 reports the year ahead. Each asks for the names and addresses of any professional solicitors, professional fundraising counsel, and commercial co-venturers engaged.

A narrow exemption exists. Organizations that raise no more than $5,000 in a calendar year (or receive contributions from no more than ten people), where all functions including fundraising are handled entirely by unpaid volunteers, are not required to hold a solicitation certificate and may be exempt from these schedules.⁷ Both conditions must be met.

Signatures

The statute requires the annual report to be signed by an authorized officer and verified under oath.² The form itself calls for at least two signatures; the president or another authorized officer or trustee must sign.⁷ Line up your signers before you start uploading, because the portal won’t accept the filing without them.

Submitting Through the Charity Portal

All Form PC filings go through the AGO’s online Charity Portal at masscharities.force.com.⁹ First-time users create an account; the AGO provides downloadable setup instructions on the same page.

Once you’re in, use the eForm PC to enter your financial data and upload scanned copies of your signed form, your IRS return, and any required audit or review statements. The portal walks through each section and blocks submission until required fields are populated. After the documents load, the system calculates your filing fee from the gross support and revenue figure you reported. Payment is by credit card or electronic check. After it clears, the portal generates a confirmation and receipt. Save both.

Filing Fees

The fee is set by statute on a sliding scale tied to gross support and revenue for the fiscal year being reported:²

$100,000 or less: $35
$100,001 to $250,000: $70
$250,001 to $500,000: $125
$500,001 to $1,000,000: $250
$1,000,001 to $10,000,000: $500
$10,000,001 to $100,000,000: $1,000
Over $100,000,000: $2,000

What Happens If You File Late or Not at All

The consequences run at both levels of government. At the state level, the Attorney General’s office has enforcement authority under M.G.L. c. 12, § 8F over delinquent charities that fail to file or pay required fees.²

The federal side is more concrete. The IRS charges a daily penalty scaled to organization size. For organizations with gross receipts under $1,208,500, the penalty is $25 per day, capped at $12,000 or 5 percent of gross receipts. For larger organizations, it is $130 per day, capped at $60,000 or 5 percent of gross receipts. If a required annual return is missed for three consecutive years, the IRS automatically revokes tax-exempt status, and reinstatement requires a new application and its fee.¹⁰

Records to Keep

There is no single federal rule dictating retention periods for every nonprofit document, but standard practice is to keep tax returns permanently. Treat your Form PC filings, IRS confirmations, and Charity Portal payment receipts the same way. They are your proof of compliance if questions come up years down the road.

1
Mass.gov. Online Charity Filing Portal
2
General Court of Massachusetts. Massachusetts General Laws Chapter 12 Section 8F
3
Office of the Attorney General. Frequently Asked Questions about Charitable Organizations
4
Internal Revenue Service. Instructions for Form 8868
5
Internal Revenue Service. About Form 990, Return of Organization Exempt from Income Tax
6
Mass.gov. Audits and Reviews for Charitable Organizations
7
Massachusetts Office of the Attorney General. Massachusetts Form PC
8
Internal Revenue Service. Instructions for Schedule L (Form 990)
9
Office of the Attorney General. Non-Profit Organizations/Public Charities Forms
10
Internal Revenue Service. Automatic Revocation of Exemption for Non-Filing – Frequently Asked Questions