Charitable Registration Harmonization

Nearly every state requires a nonprofit that solicits charitable donations from its residents to register before doing so, and most require annual renewal with their own form, fee, and financial-disclosure requirements. A national association foundation that solicits donors across the country — for scholarship funds, disaster relief, or a research foundation tied to the parent association — is required to register separately in each state where it solicits, which in practice means dozens of separate filings maintained on dozens of separate renewal calendars. NANA's position is that this is a paperwork burden with no real donor-protection benefit beyond what a single, shared filing standard would already provide.

A Unified Registration Statement already exists and is accepted by a majority of states, which helps, but several states still require their own supplemental form or refuse to accept the unified statement outright, so "harmonization" in practice still means maintaining two filing systems rather than one. Benjamin Oduya, NANA's board secretary and general counsel at the Coalition of Independent Museums, has reviewed the charitable-registration brief against the NANA Foundation's own filing calendar as the working example members can compare against.

Any association that runs a related charitable foundation and solicits donations by mail, online, or through an annual appeal is affected, which includes most NANA members with a scholarship or research arm. The compliance risk is not dramatic in any single state — a missed renewal typically means a late fee and a compliance letter, not an immediate loss of charitable status — but the cumulative administrative cost of tracking dozens of state deadlines falls hardest on small foundations run by the same one or two staff who also run the parent association's membership operations.

Lapsed registrations are also visible to donors and grantmakers who check charity-registration databases before giving, so a lapse that would be a minor paperwork problem internally can look, from outside, like the foundation is not in good standing.

NANA is asking the states that have not yet adopted the Unified Registration Statement to do so, and asking states that have adopted it but still require a state-specific supplemental form to drop the supplement in favor of the unified filing alone. This is a state-by-state ask rather than a federal one, since charitable-solicitation registration is state law, and NANA's policy team is coordinating with state association groups that share the same multistate filing burden rather than pursuing this alone.

Short of full adoption, NANA's brief recommends foundations build a single internal filing calendar keyed to the unified statement's renewal cycle, using state-specific supplements as the exception to track rather than the default assumption.