Michigan Charity Search: Registration, Renewal, and Exemptions

Any organization that asks the Michigan public for donations must register with the Attorney General’s Charitable Trust Section before making the first solicitation, unless it qualifies for a specific exemption. That single rule is the core of Michigan charity registration requirements, and it comes from the Charitable Organizations and Solicitations Act (MCL 400.271 et seq.). What follows below is what to file, when to renew, when you can skip the filing, and what happens if you don’t.

Who Has to Register

Michigan defines a charitable organization broadly: any benevolent, educational, philanthropic, humane, patriotic, or eleemosynary organization that solicits or receives contributions from the public for charitable purposes.¹ The definition reaches local nonprofits, Michigan chapters of national groups, and anyone soliciting in Michigan for a charity based somewhere else.

Three categories fall outside the definition entirely. Religious organizations with federal tax-exempt status (or whose parent has it) are not treated as charitable organizations under the act, so long as no net income benefits any individual. Political candidates, campaign committees under the Michigan Campaign Finance Act, and qualified political parties are also excluded.¹

If your organization doesn’t fit one of those carve-outs, you need to register before the first ask. Timing matters. Registration is not something to catch up on after a fundraising campaign starts.

What the Registration Filing Includes

The registration form prescribed by the Attorney General asks for detailed organizational information.² Expect to provide:

The organization’s legal name, any names used for solicitation, its principal address, and every Michigan office address. If there’s no principal office, the name and address of whoever holds the financial records.
Names and addresses of all officers, directors, trustees, the chief executive officer, and the organization’s state agent.
Where and when the organization was established, its legal form, its tax-exempt status, and whether it has ever been enjoined from soliciting.
The organization’s purpose, intended use of contributions, fiscal year, and every method of solicitation it plans to use.
Copies of any contracts with professional fundraisers, including compensation terms.

The state agent is the person designated to receive legal communications on the organization’s behalf in Michigan. The statute uses that term rather than “registered agent,” and the name has to appear on the form.²

Fundraiser contracts signed after the registration is filed must be sent to the Attorney General within 10 days.²

Financial Statements: Which Tier Applies to You

Michigan ties the financial reporting piece of registration to how much your organization received in contributions during its preceding tax year, as reported on the IRS Form 990 series return. The statutory baselines are $500,000 for audited statements and $250,000 for reviewed statements, and both amounts step up by $25,000 every five years starting in 2015.³ For registration statements submitted from 2025 through 2029, the tiers are:

$575,000 or more in contributions: financial statements prepared under generally accepted accounting principles and audited by an independent certified public accountant.
$325,000 to $574,999: financial statements either reviewed or audited by an independent CPA.
Below $325,000: no independent CPA review or audit is required with the registration, though financial information still has to be provided.

The Attorney General can waive the CPA requirement one time for a given organization. That’s a narrow safety valve, not a workaround, and it’s not something to rely on year after year.³

Renewing Every Year

Registration in Michigan is not a one-time filing. It expires seven months after the end of the organization’s fiscal year, and the CTS-02 Renewal Solicitation Form has to be submitted at least 30 days before that expiration date.⁴ The renewal has to carry updated financial statements that meet whatever tier your contribution level puts you in.

Miss the deadline and the organization can no longer legally solicit in Michigan until it files. That includes routine appeals, event sponsorships, and online donation forms visible to Michigan residents.

Exemptions

Section 13 of the act exempts certain organizations from the registration and reporting requirements. The religious organization exemption is baked into the definition itself, so churches and their integral affiliates with federal tax-exempt status aren’t treated as charitable organizations under the act to begin with.¹

Smaller organizations that receive limited contributions and don’t pay anyone for fundraising may qualify for reduced or waived requirements. If you think you fit, submit an exemption request through the Attorney General’s online filing system.⁴ An exemption doesn’t mean the Attorney General loses interest in your records. The office can still request financial documentation, and exempt organizations should be ready to produce it.

If You Use a Professional Fundraiser

Hiring a professional fundraiser adds obligations on both sides. The charity has to file copies of every fundraiser contract with the Attorney General as part of its registration, and any contract signed after the initial filing must be submitted within 10 days.²

Professional fundraisers themselves have to be licensed and bonded. For public safety fundraisers soliciting in Michigan for the first time, the surety bond is $25,000. After the first year, the bond amount is tied to what the fundraiser collected in the previous year.⁵

Both the charity and the fundraiser must keep copies of their contracts through the entire term of the engagement and for six years after the solicitation ends.¹ Bringing on a professional fundraiser doesn’t move the compliance burden entirely off the charity. The organization is still responsible for filing the contract and confirming its fundraising partner is properly licensed.

Records to Keep

Charitable organizations and their agents must maintain accurate and detailed books and records at the office of their state agent. Those records should cover income, expenditures, and how funds are split between programs and overhead. The six-year retention rule that applies to professional fundraiser contracts is a reasonable benchmark for other financial records too.¹

The Attorney General can request financial documentation at any time, including from organizations that are exempt from registration. Thin records turn routine inquiries into full compliance problems, because the default assumption when documentation is missing isn’t that things were fine but poorly filed.

Federal Return Reference Point

Michigan’s contribution thresholds are keyed to figures reported on IRS Form 990 series returns, so the federal return does double duty. Whether an organization files the full Form 990, the 990-EZ, or the 990-N depends on gross receipts and total assets, and small 501(c)(3) organizations with gross receipts normally at or below $5,000, along with churches and their integrated auxiliaries, are exempt from filing altogether.⁶ Whatever return your organization files, the contribution figure it reports is what determines your Michigan financial statement tier.

Penalties for Not Registering

Michigan treats registration and solicitation violations as criminal matters. Under MCL 400.293, a person who knowingly engages in deceptive solicitation practices commits a misdemeanor punishable by up to six months in jail, a fine of up to $5,000, or both, for each violation.⁷ Prohibited conduct includes:

Misleading anyone into believing a solicitation is for a charitable organization when it is not.
Diverting contributions to a purpose or organization other than what donors were told.
Misrepresenting that donations will go toward a specific charitable purpose.
Falsely claiming a donor will receive special benefits or face unfavorable treatment for not giving.
Using any fraudulent scheme to obtain money through false representations.
Failing to file required materials with the Attorney General.

That last item is where a charity that simply forgot to renew ends up. Using deceptive names, bogus organizations, fictitious addresses, or false claims of government endorsement to extract between $1,000 and $5,000 in aggregate is also charged as a misdemeanor under the same penalty structure.⁷

The Attorney General can also seek injunctions to halt fundraising and accept assurances of discontinuance from organizations that agree to stop violating the act. For a charity that depends on public trust to raise money, publicized enforcement can hurt more than the fine.

Michigan Registration Doesn’t Cover Other States

Registering with the Michigan Attorney General authorizes solicitation in Michigan and nothing else. Roughly 40 states require some form of charitable solicitation registration, and the guidelines known as the Charleston Principles treat even a passive “donate now” button on a website as potentially triggering obligations in states where the organization receives substantial or repeated contributions. Once an online donation portal is live, most states that regulate charitable solicitation are likely in play. Each has its own forms, fees, and renewal calendar, and a Michigan filing does no work in any of them.

1
Michigan Legislature. Michigan Compiled Laws Act 169 of 1975 – Charitable Organizations and Solicitations Act
2
Michigan Legislature. Michigan Compiled Laws 400.273 – Charitable Organization; Registration; Information to Be Included in Registration Statement
3
Michigan Legislature. Michigan Compiled Laws 400.273 – Charitable Organization; Registration
4
Michigan Attorney General. Charitable Organizations
5
Michigan Attorney General. Public Safety Organizations and Their Fundraisers
6
Office of the Law Revision Counsel. 26 USC 6033 – Returns by Exempt Organizations
7
Michigan Legislature. Michigan Compiled Laws 400.293 – Violations and Penalties