Changes to contribution revenue thresholds may impact your not-for-profit’s financial statement audit or review requirements

Most states in the U.S. have compliance requirements for charitable organizations receiving contribution revenue. The laws can vary state-by-state in terms of how each state defines “contributions,” not to mention the dollar thresholds in each state dictating if a charitable organization is required to obtain a financial statement audit or review from an independent certified public accountant (CPA).

In recent months, legislative changes in Wisconsin and Illinois were announced by their respective regulatory agencies to modify the financial thresholds they have in place to determine if an audited or reviewed financial statement is required for charitable organizations.

Updates impacting charitable organizations

Wisconsin

In Wisconsin, contribution revenue drives the audited and reviewed financial statement requirement and the state has generally defined “contribution revenue” as any contribution of cash or property, excluding grants from governmental entities.

In recent years, the audit and review thresholds were set at $500,000 and $300,000 of contribution revenue, respectively, prior to the new legislation recently put into effect.

Changes were implemented in March 2024 to increase these thresholds and under the new law, charitable organizations with contribution revenue as defined above over $1,000,000 would be required to obtain an audit and over $500,000 would require a financial statement review.

This change in Wisconsin is effective for charitable organizations with tax years beginning after March 23, 2024.

Illinois

Meanwhile in Illinois, the laws differ both in terms of the dollar thresholds in place, as well as how “contributions” are defined by the state.

Compared to Wisconsin, Illinois defines contributions more broadly – including the gross receipts of cash donations as well as gross amounts paid by the public for merchandise, special events, rights or services of the organization.

Previous Illinois law set the audit threshold at $300,000 of contributions as defined above and no threshold was previously in place for a financial statement review.

Under the recent legislation, however, Illinois increased the audit threshold to $500,000 and created a new $300,000 threshold to require a financial statement review.

These changes go into effect for charitable organizations with Illinois Form AG990-IL annual reports due after Jan. 1, 2024, (without considering any extension to file). In other words, charitable organizations with fiscal years ending July 31, 2023, and later would be impacted under the new requirements.

Key takeaways

Depending on what fiscal year a charitable organization operates and where the organization’s budget and projected growth is trending, these changes may impact some organizations sooner than others.  Management should be aware of these requirements and when the changes would go into effect for their organization.

Wondering about the next steps for your organization? Reach out to your Baker Tilly advisor or connect with our NFP specialists.