Update on “BCO-10” -- the Pennsylvania

Charitable Organization Registration Statement

By Karen Burns, CPA

Malin, Bergquist & Company, LLP

The Charitable Organization Registration Statement for Pennsylvania, commonly known as the BCO-10, is a required filing for most PA charitable organizations filing a Federal Form 990.  As with most government regulations, there are some exceptions to the filing requirements of the BCO-10. 

The following charitable organizations, although not all inclusive, are exempt from the registration requirements:  educational institutions, hospitals subject to regulation by the Department of Health or Department of Public Welfare, public nonprofit library organizations, and any charitable organization which receives contributions of $25,000 or less annually, provided that such organization does not compensate any person who conducts solicitations.

The BCO-10 is required to be filed 135 days after the organization’s year end.  The date of this filing does not always coincide with the Federal Form 990; often times it is due a few days before.  Fees related to the BCO-10 vary based on the total contributions reported on Federal Form 990. Fees can range from $15 to $250. 

In the past, the Bureau of Charitable Organizations required organizations to file an extension (up to 180 days) if they were unable to file the BCO-10 on a timely basis.  The extension request was filed on form BCO-2. 

However, this part of the requirements has changed.  Eligible organizations automatically receive a 180 day extension if they are unable to file the return within the 135 day period.  Eligible organizations are those that have filed the previous years BCO-10 and are in an approved status with the bureau.  If you are not in an approved status for previous years (i.e. have not filed the BCO-10 in previous years), the bureau will not grant an extension to the organization.

There are two ways to determine eligibility.  Visit the website (http://www.dos.state.pa.us/portal/server.pt/community/charities/12444) and search the database to determine if they are in approved status, or contact the Bureau of Charitable Organizations toll-free at 1-800-732-0999.  The bureau will send out extension notices if an organization requests a paper copy. 

In recent years, the Internal Revenue Service has increased the minimum criteria that determines if not-for-profit organizations can file abbreviated information returns. For those organizations not required to file the full Form 990 and instead file Forms 990-N, 990-EZ, or 990-PF, there is a requirement to complete the Pennsylvania Public Disclosure Form (BCO-23).

The fee for filing the BCO-23 is $15.  The BCO-23 is due within the same time frame as the BCO-10 stated in paragraphs above, 135 days after the organization’s year end. 

Karen Burns, CPA is a member of the Not-for-Profit/Tax Exempt Organizations Group of the public accounting firm of Malin Bergquist, of Erie and Pittsburgh, PA, and which serves 150 non-profit clients each year. Contact her at 814.454.4008 or at kburns@malinbergquist.com.