If your organization solicits charitable contributions from Pennsylvania residents, you may be required to register with the Pennsylvania Bureau of Corporations and Charitable Organizations to obtain a unique registration number commonly referred to as a BCO ID.
Failing to register, or missing a renewal deadline, can result in mandatory late fees that cannot be waived under any circumstances.
Here is what your organization should know.
What Is a BCO Registration?
The BCO-10 (Charitable Organization Registration Statement) is the form used to initially register and annually renew a charitable organization’s authority to solicit contributions from Pennsylvania residents. It is administered by the Pennsylvania Bureau of Corporations and Charitable Organizations under the Pennsylvania Solicitation of Funds for Charitable Purposes Act, 10 P.S. §162.1 et seq.
Upon approval, your organization receives a Certificate of Registration bearing your BCO ID number. This number is required on all future renewal filings and correspondence with the Bureau.
Does My Organization Need to Register?
You are required to register if your organization solicits charitable contributions from Pennsylvania residents and meets the definition of a charitable organization under Pennsylvania law.
A charitable organization is broadly defined as:
- Any organization granted tax-exempt status under IRC §501(c)(3).
- Any organization established for a charitable purpose.
- Any organization that uses a charitable appeal as the basis of any solicitation.
“Charitable purpose” includes benevolent, educational, philanthropic, humane, scientific, patriotic, social welfare, advocacy, public health, environmental conservation, civic, and related objectives.
Exemptions and Exclusions
Not every charitable organization is required to register. Pennsylvania law provides for certain exclusions and exemptions from the Act, including organizations such as hospitals, public libraries, nursing homes, and parent-teacher associations. The Bureau maintains a full Exclusions and Exemptions Chart at dos.pa.gov/charities.
Even if your organization is exempt, voluntary registration is available. Organizations that voluntarily register must comply with all Act requirements, except the payment of late filing fees.
When Must You Register?
The timing of your initial registration depends on whether your organization compensates anyone for soliciting:
- If your organization uses paid solicitors: Registration is required before any compensated solicitation begins.
- If all solicitation is uncompensated (volunteer-based): Registration is required within 30 days of receiving more than $25,000 in gross contributions.
What Do You Need to Submit?
Registration requires compiling several documents including:
- Completed BCO-10 form — signed by two different officers, one of whom must be the chief fiscal officer.
- IRS Form 990, 990EZ, 990PF, or 990N — a completed, signed copy with all applicable schedules for the immediately preceding fiscal year. (Do not include Schedule B unless filing a 990PF.)
- BCO-23 (Pennsylvania Public Disclosure Form) — required if your organization is not required to file a 990, or if filing a 990N, 990EZ, or 990PF.
- Financial statements for the immediately preceding fiscal year (the type required depends on your gross annual contributions — see the fee chart below).
- Registration fee payable to “Commonwealth of Pennsylvania.”
Initial Registrants Only (Additional Items): - Copy of your IRS tax-exemption determination letter.
- Organizational documents — charter or articles of incorporation.
- Bylaws.
All submissions must be mailed; electronic filing is not available. Every question on the BCO-10 must be answered, even if the answer is “N/A.” Leaving questions blank will result in a deficiency letter and may trigger late fees.
Registration Fees and Financial Statement Requirements
Both your registration fee and the type of financial statement required are based on your organization’s gross annual contributions, meaning total contributions from all sources nationally, not just from Pennsylvania.
| Gross Annual Contributions | Registration Fee | Financial Statement Required |
|---|---|---|
| Section 162.7(a) organizations | $15 | None |
| $25,000 or less | $15 | Internally Prepared, Compiled, Reviewed, or Audited |
| $25,001 – $99,999 | $100 | Internally Prepared, Compiled, Reviewed, or Audited |
| $100,000 – $249,999 | $150 | Compiled, Reviewed, or Audited |
| $250,000 – $749,999 | $150 | Reviewed or Audited |
| $750,000 or more | $200 | Audited |
Compiled, reviewed, and audited financial statements must be prepared by an independent licensed CPA or public accountant in accordance with AICPA standards.
Annual Renewal Requirements
The BCO-10 is used for both initial registration and annual renewal. Your renewal deadline is printed on your Certificate of Registration, but as a general rule, renewals must be postmarked no later than the 15th day of the 11th month following the close of your organization’s fiscal year.
For example, if your fiscal year ends December 31st, your renewal is due by November 15th of the following year.
The Bureau strongly encourages early submission to avoid any gaps in your registration status. If you provide an email address on your registration, the Bureau will send renewal reminders and your Certificate of Registration electronically rather than by mail.
If your organization misses its renewal deadline, a late filing fee of $25 per calendar month (or any part of a month) will be assessed from the due date forward.
These fees are statutorily required and cannot be waived under any circumstances — not even for first-time violations or extenuating circumstances. Keeping your mailing address and email current with the Bureau is critical to ensure you receive renewal reminders and do not inadvertently miss a deadline.
Ongoing Compliance Obligations
Registration is not a one-time event. Once registered, your organization must:
- Report material changes in any filed information to the Bureau in writing within 30 days of the change occurring.
- Report any change in IRS tax-exempt status — including denial, revocation, or modification, with supporting documentation on the first filing after the change occurs.
- Keep your contact information current to avoid missing Bureau correspondence.
Parent Organizations and Affiliates
If your organization has Pennsylvania-based affiliates, the parent organization may file a combined registration on behalf of itself and its affiliates. Under a combined filing:
- Both the parent and each affiliate must file a separate BCO-10 and their own IRS 990 or BCO-23.
- The parent’s registration fee is calculated based on the combined gross contributions of the parent and all Pennsylvania affiliates.
- The parent must submit financial statements covering itself and all Pennsylvania affiliates.
- Affiliates covered under a combined filing do not pay a separate registration fee.
Need Help Navigating the Registration Process?
BCO registration may seem straightforward, but the requirements, particularly around financial statements, affiliate filings, and renewal deadlines, can be easy to get wrong. At Aevitas Law, we work with Pennsylvania nonprofits and charitable organizations to ensure their registrations are complete, accurate, and filed on time.
Contact us today to learn how we can help your organization stay compliant and focused on its mission.
