Form CT-TR-1: who has to file it, and who does not
There is no revenue threshold for this form. There is one test, and it is the federal return you filed.
The Attorney General’s Registry of Charities and Fundraisers decides this by one test, and it is not revenue. If your organization files the IRS Form 990-N, you must file Form CT-TR-1 with your RRF-1.
If you file a Form 990, 990-EZ or 990-PF, you file a copy of that return instead, and CT-TR-1 is not required.
The rule, in the Registry’s own words
Most of the confusion about this form comes from guessing at a revenue threshold. There isn’t one. The Registry ties it to the federal return you file:
“If your organization is eligible to file, and does file, IRS Form 990-N with the IRS, the organization is required to file Form CT-TR-1.”
And the other direction, just as plainly:
“Registrants who file IRS Form 990, Form 990-EZ or Form 990-PF with the IRS must also file the same with the Registry as part of their annual filing, even if they were eligible to file IRS Form 990-N with the IRS. Form CT-TR-1 is not required from these registrants.”
Read that second sentence twice, because it carries a trap. An organization small enough to use the 990-N may choose to file a 990-EZ anyway, and some boards prefer the fuller return while some grantmakers ask for it. The moment you do, CT-TR-1 drops away and a copy of the 990-EZ takes its place. The deciding fact is what you actually filed, not what you were entitled to file.
What the form is
CT-TR-1 is the Annual Treasurer’s Report. It exists because the 990-N tells the Registry almost nothing. The e-Postcard is eight data points with no financial statement of any kind. California still wants to see where the money came from and where it went, so a small organization that files the e-Postcard federally files CT-TR-1 at the state level to fill that gap.
It is filed with Form RRF-1, not instead of it. RRF-1 is the annual registration renewal. CT-TR-1 is the financial attachment that comes with it for 990-N filers.
When it is due
The same date as the RRF-1 it travels with:
“Required annual filings and registration fees are due 4 months and 15 days after the charitable organization’s fiscal year ends unless the IRS has granted an extension.”
For a 31 December year end, that is 15 May.
If you extend the federal return, this moves with it:
“The Registry of Charities and Fundraisers honors all IRS extensions for annual renewal filing deadlines for charities.”
Order matters. The Registry adds one piece of sequencing worth knowing: registrants granted an extension of time from the IRS should not file with the Registry before filing with the IRS.
Private foundations
A private foundation files Form 990-PF federally, “regardless of financial status” in the IRS’s words. A 990-PF filer is one of the registrants from whom, in the Registry’s words, “Form CT-TR-1 is not required.” The copy of the 990-PF does that job.
What it costs
Nothing by itself. The fee that accompanies the annual filing is the RRF-1 renewal fee, set by total revenue.
| Total revenue | Fee |
|---|---|
| Less than $50,000 | $25 |
| Between $50,000 and $100,000 | $50 |
| $100,001 to $250,000 | $75 |
| $250,001 to $1 million | $100 |
| Above $1 million | $200 to $1,200, by band |
Published by the Registry as of 1 January 2022 under California Code of Regulations, title 11, section 306.
What happens if you skip it
An incomplete annual filing is a late annual filing. The Registry describes the consequences of not renewing as late fees, penalties, and a delinquent, suspended or revoked registration status, and it is explicit about what that status costs:
“A charitable organization that is not in good standing with the Registry because of delinquency, suspension, or revocation may not operate or solicit donations in California.”
That is the sentence that should get a board’s attention. Not a fine. The right to ask for money in your own state.
Common questions
Does filing the 990-N with the IRS mean we are done?
No. The 990-N satisfies the IRS. California’s Attorney General separately requires Form RRF-1, and because you filed the 990-N, Form CT-TR-1 with it.
We filed a 990-EZ even though we could have filed the 990-N. Do we still file CT-TR-1?
No. You attach a copy of the 990-EZ instead. The Registry’s rule turns on the return you filed, not the one you were eligible for.
Is there a revenue threshold for CT-TR-1?
No. It is decided entirely by which federal return you file.
When is CT-TR-1 due?
With the RRF-1, four months and fifteen days after your fiscal year ends, which is 15 May for a 31 December year end, unless the IRS has granted an extension. The Registry honors IRS extensions.
Do private foundations file CT-TR-1?
No. A private foundation files Form 990-PF and submits a copy of it to the Registry.
What if we are already late?
File. A delinquent registration can usually be cured, and the cost of curing it is far below the cost of losing the ability to solicit. Bring us the years you are missing and we will work out the order.
This article is general information about California and federal filing requirements, current as of the date shown. It is not tax, legal, or financial advice for your situation, and reading it does not create a client relationship. Rules change and individual facts matter. Confirm how any of this applies to you before acting on it.
Primary sources
- California Attorney General, Registry of Charities and Fundraisers — Annual renewal
- California Attorney General, Registry of Charities and Fundraisers — Delinquency
- IRS — Annual electronic filing requirement for small exempt organizations, Form 990-N
- IRS — Form 990 series: which forms do exempt organizations file
Published 2 October 2026. Every quoted sentence is the agency’s own, checked against the agency’s published page on that date.
One form, and a rule people get backwards.
If you are not sure which return your organization filed last year, or whether the Registry has what it needs, we will check it with you. Every engagement is personally led and reviewed by founder Avneet Saini.
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