The Soapbox and Toolbox for New York State's Nonprofits

January 20, 2015

We Get That a Lot: The New Rules for Nonprofit Audits under the NPRA

Are the new rules for audit thresholds confusing you too? We get a lot of questions about how to go about determining what kind of review or audit our nonprofit members need. Here is a guide for New York nonprofits from the Attorney General's Charities Bureau. If you have questions and are a NYCON Member, please contact us.


Attorney General Eric Schneiderman
Charities Bureau
Guidance Document 2014-1
Issue date: April 15, 2014

Guidance on Provisions of the Nonprofit Revitalization Act of 2013
Revised CPA Review and Audit Thresholds and Annual Filing Fees for 7A or DUAL Filers

The Nonprofit Revitalization Act of 2013, proposed by Attorney General Eric T. Schneiderman and
based on recommendation of the Leadership Committee for Nonprofit Revitalization he formed,
becomes effective on July 1, 2014. The Act changed the filing requirements and filing fees mandated
by Article 7-A of the Executive Law, exempting smaller organizations from the requirement to file a
CPA's audit or review report and financial statements. This change affects certain organizations
registered with the Charities Bureau to solicit contributions in New York pursuant to Article 7-A of
the Executive Law and required to file either an independent Certified Public Accountant's review or
audit with their financial statements because their revenue exceeds the thresholds described in the
charts below. Organizations required to register under Article 7-A are categorized by the Charities
Bureau as “7A” or “DUAL” organizations. To find the registration category of a particular
organization, please consult our searchable Charities Bureau Registry.

7A and DUAL organizations are required to file their annual financial reports and pay an annual
filing fee within four and one-half months after the end of their fiscal year unless the filing date has
been extended. For example, if an organization's fiscal year ended on December 31, 2013, it must
file its annual report by May 15, 2014 unless it has requested an extension of time to file. The
Charities Bureau typically will grant an extension of up to six months, in which case an organization
whose fiscal year ended on December 31, 2013 will have until November 15, 2014 to file its report.
Visit our website to review instructions for requesting an extension of time
to file and forms and instructions for filing annual reports.

The Act raised the revenue thresholds requiring registered organizations to file either an independent
Certified Public Accountant’s ("CPA") review or audit report. Those thresholds are based on the
organization's gross revenue and support during the reporting year, which includes all income received
by the organization from any source, including contributions, grants, fees and other types of revenues.
An audit of financial statements is performed by a CPA to determine whether the organization has
appropriately reported its financial activities in accordance with a prescribed method of accounting
(e.g., generally accepted accounting principles). An audit includes performing procedures to obtain
evidence about the amounts and disclosures in the financial statements, assessing the risks of material
misstatements in the financial statements, and considering internal controls relevant to the preparation
and fair presentation of the financial statements. Financial statements typically consist of the
statement of financial position (balance sheet), statement of activities, statement of functional
expenses (if applicable), statement of cash flows, and notes to financial statements.

A review of financial statements performed by a CPA involves the performance of analytical tests to
the financial data as well as inquiries of personnel in order to obtain limited assurance that there are
no material modifications that should be made to the financial statements in order for them to be in
conformity with a prescribed method of accounting (e.g., generally accepted accounting principles).
It does not include audit procedures such as assessing fraud risk or testing records, and accordingly is
a lesser level of assurance than an audit.


The newly enacted thresholds and the annual filing fees are as follows:


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NYCON develops and promotes an effective and vibrant charitable nonprofit community throughout New York State.  We strengthen organizational capacity, act as an advocate and unifying voice, help to inform philanthropic giving, and conduct research and planning to demonstrate relevance and impact.