Michigan Solicitation License: Registration, Renewal, and Penalties

If your nonprofit plans to ask the public for money in Michigan, you almost certainly need a Michigan solicitation license, which the state issues as a charitable organization registration through the Attorney General’s Charitable Trust Section. The requirement comes from the Charitable Organizations and Solicitations Act (Public Act 169 of 1975), and it applies before any fundraising begins.¹

Who Has to Register

Any organization that solicits or intends to solicit contributions from the Michigan public must register with the Attorney General before it starts. The method doesn’t matter: direct mail, events, phone campaigns, door-to-door, and online fundraising are all covered. Out-of-state charities soliciting into Michigan are covered too.²

One rule catches small nonprofits off guard. If you pay anyone to raise money on your behalf, you have to register even if your total contributions stay below $25,000 a year.³ The small-organization exemption is only available when every person doing the fundraising is an unpaid volunteer.

Who Is Exempt

Several categories of organizations are exempt from registration and reporting, but the conditions are narrower than they look. The exempt categories include:⁴

Small volunteer-only organizations that receive no more than $25,000 in any 12-month period and make a financial statement available to members and the public. Cross the $25,000 line and you have 30 days to register.
Groups that solicit only among their own members, directors, trustees, and those individuals’ immediate families, and that do not invite the general public to join.
Schools certified by the Michigan State Board of Education.
Veterans’ organizations incorporated under federal law.
Licensed hospitals and hospital-based foundations or auxiliaries that solicit funds solely for one or more licensed hospitals.
Organizations funded exclusively by a registered charity, that do not solicit from anyone else, and that make a financial statement public.
Non-501(c)(3) service organizations whose primary purpose isn’t charitable but that occasionally solicit charitably using only unpaid members. They must still file a Form 990 or 990-EZ with the Attorney General.
Solicitations for a specific named individual, done by unpaid volunteers, where proceeds go to that person after reasonable costs.

Religious organizations sit outside the Act’s definition of “charitable organization” entirely, so long as they have current tax-exempt status and no net income benefits any individual directly.¹ The exclusion is written around congregations supported by their own members. A religious organization that moves into general public fundraising beyond its congregation may fall outside that safe harbor, and the line is worth reviewing with counsel.

If you’re not sure where you land, the Attorney General’s office suggests filing a Request for Exemption Form before starting a full registration.³

How to File

Registration goes through the Attorney General’s Charitable Trust Section. You can file electronically through the state’s e-filing portal, or send forms by email, mail, or fax.³ The mailing address is:

Charitable Trust Section
P.O. Box 30214
Lansing, MI 48909-7714

The application asks for the names and addresses of your officers, directors, trustees, and chief executive officer; where and when the organization was legally established; its tax-exempt status; and the details of your planned solicitation activities. If you use a professional fundraiser, contract copies go in with the filing. An authorized officer signs the application, confirming its accuracy.¹

Financial Statements You Have to Include

What financial documentation you submit depends on your contribution level. Michigan adjusts these thresholds every five years. For registrations filed between January 1, 2025 and December 31, 2029:⁵

$575,000 or more in contributions: financial statements prepared under generally accepted accounting principles and audited by an independent CPA.
$325,000 to $574,999: financial statements either reviewed or audited by an independent CPA. The Attorney General can waive this once for a given organization.
Below $325,000: financial statements are still required, but do not have to be professionally reviewed or audited.

Contribution amounts come from your most recent IRS Form 990, 990-EZ, 990-PF, or other 990-series return. Michigan’s e-filing system can also prepare and file your Form 990 with the IRS at the same time, though a fee applies if your gross receipts exceed $100,000.⁶

When the License Expires and How to Renew

Michigan’s renewal clock doesn’t run on a fixed calendar date. Your registration expires one year and seven months after the end date of the financial statement you filed with your most recent registration.⁷ The deadline is tied to your fiscal year, not to the date you first registered, so calculate it from your books.

You must file a renewal registration statement and updated supporting information at least 30 days before the current registration expires. Renewal calls for current financial statements at the same thresholds, updated officer and director information, and any changes to tax-exempt status or solicitation activities.⁷

Need more time? The Attorney General’s office grants a five-month extension if you request it in writing before the registration expires.³ If you miss the deadline and don’t extend, your registration lapses, and any fundraising you do during the gap is technically unauthorized solicitation.

Separately, you must notify the Attorney General within 30 days of any change to the information in your registration, including changes in leadership, solicitation methods, or organizational structure. Don’t hold updates for the renewal cycle.

If You Use a Paid Fundraiser

Michigan distinguishes between a professional fundraiser, who plans, conducts, or manages a solicitation campaign for pay, and a professional solicitor, who is employed by that fundraiser to make the actual solicitation contacts.¹ A staff member whose salary isn’t tied to what’s raised is not a professional fundraiser. Compensation calculated on funds raised or to be raised triggers the professional fundraiser rules.

Professional fundraisers must file a license application with the Attorney General before starting work. The definition also reaches operators of clothing donation boxes that imply the items benefit a charity by displaying a charity’s name or logo.¹

Contracts between a charity and a professional fundraiser have to be kept at both offices for the entire engagement and for six years after the campaign ends.¹ Charities that rotate through fundraising firms should build a retention system before older contracts get lost.

Penalties for Fundraising Without a License

Solicitation without proper registration exposes both the organization and the individuals behind it.

Civil Fines

A court can impose a civil fine of up to $10,000 for each violation of the Act. Fines can be assessed against the organization, its officers, directors, shareholders, controlling members, or anyone who directly engaged in or authorized the conduct. If a court issues an injunction and it is violated, that carries another $10,000 per violation.¹

The Attorney General can also seek injunctions halting all solicitation, restitution to affected donors, and recovery of attorney fees and investigation costs. Short of court, the office can issue cease and desist orders or accept an assurance of discontinuance that may include escrow of funds or restitution payments.¹

Criminal Charges

Knowing violations are misdemeanors punishable by up to six months in jail, a fine of up to $5,000, or both, for each violation. The covered acts include:⁸

Misleading someone into believing an organization is a charity or that proceeds go to charitable purposes when they don’t.
Redirecting contributions to a purpose or organization other than what donors were told.
Misrepresenting that donations will fund a specific charitable purpose or that donors will receive special treatment.
Using any deceptive device to obtain money or property through false representations.
Knowingly failing to submit required materials, information, or reports under the Act.

Certain deceptive practices, such as using a bogus organization name or impersonating a government-endorsed charity, also qualify as misdemeanors under the same penalty structure when the wrongful conduct produces aggregate gains between $1,000 and $5,000.⁸ These charges reach individuals, not just the organization. Officers and directors who authorize or take part in unauthorized solicitation face personal exposure.

The Attorney General doesn’t need a complaint to investigate. The office can act on its own initiative and can compel testimony under oath along with production of books, records, and other documents, enforced through the courts.¹ Registering before you fundraise, and keeping the file current afterward, is the cheapest form of protection available.

1
Michigan Legislature. Charitable Organizations and Solicitations Act, Act 169 of 1975
2
State of Michigan. Charitable Organizations
3
State of Michigan. Charities
4
Michigan Legislature. Michigan Compiled Laws Section 400-283 – Charitable Organizations and Solicitations Act
5
Michigan Legislature. Michigan Compiled Laws Section 400-273 – Charitable Organization; Registration
6
State of Michigan. Forms
7
Michigan Legislature. Michigan Compiled Laws Section 400-277 – Charitable Organizations and Solicitations Act
8
Michigan Legislature. Michigan Compiled Laws Section 400-293 – Charitable Organizations and Solicitations Act