Maryland Nonprofit Compliance

    Maryland Nonprofit Audit Requirements

    When does a Maryland nonprofit need an audited financial statement?

    Maryland requires charitable organizations with gross contributions over $750,000 to submit audited financial statements with their annual charitable registration renewal (COMAR 05.04.04). Organizations with contributions between $300,000 and $749,999 must submit reviewed financial statements. Below $300,000, a Form 990 or 990-EZ is sufficient. Annual registration renews within 6 months of fiscal year-end.

    Maryland Charitable Registration — Financial Requirements by Revenue

    Maryland Charitable Registration — Financial Requirements by Revenue

    FeatureRequired DocumentCPA Service NeededApproximate Cost
    Under $25,000Exempt from registrationNone
    $25,000–$299,999Form 990, 990-EZ, or 990-NNone (CPA preparation recommended)$800–$2,500
    $300,000–$749,999CPA-reviewed financial statementsFinancial statement review$3,000–$10,000
    $750,000+CPA-audited financial statementsFull financial statement audit$10,000–$30,000+
    State agency affiliated orgsAudit + AUP reportAudit + agreed-upon procedures$12,000–$35,000

    Source: COMAR 05.04.04 — Maryland Office of the Secretary of State

    Maryland Registration Deadlines

    Key Deadlines

    • Registration renewal: 6 months after fiscal year-end
    • June 30 year-end: December 31 deadline
    • December 31 year-end: June 30 deadline
    • Audit must be complete before registration renewal

    Extensions & Penalties

    • 6-month extension available if audit is pending (Form COT/FS 04)
    • Late penalty: $25/month up to $300 per registration period
    • Lapsed registration = cannot legally solicit in Maryland

    Common Maryland Compliance Mistakes

    "We didn't know our state grants count as 'contributions' for the threshold"

    Maryland counts government grants and contracts as part of gross contributions for threshold purposes. Many nonprofits funded primarily through state contracts think they're under the threshold — but they're not.

    "We're at $285K and crossed $300K this year but didn't get a review"

    If your contributions crossed the $300K threshold mid-year, the review requirement applies to your next annual registration — even if this is your first year above the threshold. Budget accordingly.

    "Our review was done by our bookkeeper, not a licensed CPA"

    Maryland requires the financial statement review to be performed by an independent CPA licensed to perform audit and attest services. An in-house accountant or unlicensed bookkeeper cannot prepare a qualifying review.

    "We missed the 6-month deadline and our registration lapsed"

    A lapsed charitable registration means you technically cannot solicit contributions in Maryland. Reinstatement requires payment of back fees and late penalties, and requires all delinquent reports to be filed.

    Key Maryland Regulatory Terms

    COMAR 05.04.04
    The Code of Maryland Regulations governing the Charitable Organizations Act, administered by the Office of the Secretary of State. It establishes registration requirements, financial reporting thresholds, and audit/review standards for charitable organizations soliciting contributions in Maryland.
    Affiliated Organization
    Under Maryland law, a charitable organization affiliated with a state agency (such as a school foundation or hospital auxiliary) may have additional audit requirements, including both a financial statement audit and an agreed-upon procedures (AUP) engagement covering the specific relationship with the state agency.

    How Your Virtual CPA Helps Maryland Nonprofits

    We specialize in Maryland charitable registration compliance for nonprofits across the DC/MD/VA region. Our services include:

    • CPA-prepared financial statement reviews meeting Maryland's COMAR 05.04.04 standards
    • Full audit engagements for organizations above the $750K threshold
    • AUP engagements for state-agency affiliated organizations
    • Form 990 and 990-EZ preparation for registration renewal filing
    • Extension request preparation (Form COT/FS 04)
    • First-year registration guidance for new Maryland nonprofits

    Related Resources

    Frequently Asked Questions — Maryland Nonprofit Audits

    Ready to Meet Maryland's Charitable Registration Requirements?

    Your Virtual CPA provides Maryland-specific nonprofit audit and review services — helping you stay compliant and keep your registration current.