Ernest L. Tomkiewicz CPA LLC
New Hampshire Nonprofit Financial Audit Requirements
Understand New Hampshire nonprofit audit requirements, including the $2 million gross revenue threshold, and annual reporting obligations for charitable organizations.








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New Hampshire charitable organizations are entrusted with significant public support, and state law requires larger nonprofits to provide greater financial transparency through independent financial statement audits. These reporting requirements help strengthen public confidence while ensuring organizations remain accountable to donors, grantmakers, and regulators.
New Hampshire’s additional financial-statement requirements apply to New Hampshire-based charitable organizations that are required to file IRS Form 990 with the Attorney General. When revenue, gains, and other support reach $2 million or more, the organization must submit its latest audited financial statement prepared in accordance with generally accepted accounting principles (GAAP). (RSA 7:28, III-b; N.H. Admin. R. Jus 404.02(b)(6))
New Hampshire measures the statutory threshold using revenue, gains, and other support rather than charitable contributions alone. Organizations should therefore evaluate the full amount reported for the fiscal year when determining whether the additional GAAP financial-statement or audit requirement applies. (RSA 7:28, III-a–III-b)
Whether your nonprofit serves Manchester, Nashua, Concord, Portsmouth, Keene, Lebanon, Dover, or communities throughout New Hampshire, planning for an audit before reaching the reporting threshold can simplify compliance and strengthen financial governance.
New Hampshire Audit Requirements at a Glance
| Requirement | Details |
| State | New Hampshire |
| Audit Threshold | $2,000,000 or more in revenue, gains, and other support |
| Measurement | Revenue, gains, and other support |
| Financial Reporting Required | Independent Financial Statement Audit |
| Lower Threshold | At $500,000 or more but less than $2,000,000, qualifying New Hampshire-based organizations submit a GAAP financial statement; a CPA review is not specifically required |
| Reporting Agency | New Hampshire Department of Justice – Charitable Trusts Unit |
| Applies To | Qualifying New Hampshire-based charitable organizations subject to RSA 7:28 / Jus 404.02 |
| Governing Authority | RSA 7:28 |
Quick Answer
If your organization is New Hampshire-based, is required to file IRS Form 990 with the Attorney General, and reports $2 million or more in revenue, gains, and other support, New Hampshire requires its latest audited financial statement prepared in accordance with GAAP. (RSA 7:28, III-b; N.H. Admin. R. Jus 404.02(b)(6))
When Does New Hampshire Require a Nonprofit Audit?
New Hampshire uses revenue, gains, and other support to determine the additional financial-statement requirement. (RSA 7:28, III-a–III-b)
Qualifying organizations generally follow this reporting structure. (RSA 7:28, III-a–III-b; N.H. Admin. R. Jus 404.02(b)(6))
| Revenue, Gains & Other Support | Financial Statement Requirement |
| Less than $500,000 | No additional GAAP financial-statement requirement under RSA 7:28, III-a based solely on this threshold* |
| $500,000 to less than $2,000,000 | GAAP financial statement (CPA review not specifically required) |
| $2,000,000 or more | Independent CPA audit |
The additional financial-statement requirement is directed to New Hampshire-based organizations. Under the current administrative rule, it applies to New Hampshire-based charitable organizations that are not private foundations and that meet the applicable revenue threshold. (N.H. Admin. R. Jus 404.02(b)(6))
Organizations approaching the $2 million threshold should begin discussing audit planning with an independent CPA well before fiscal year-end.
New Hampshire’s Headquarters Requirement
One feature that distinguishes New Hampshire from many other states is which organizations the law covers.
The current rule ties the added financial-statement requirement to New Hampshire-based charitable organizations rather than simply to every organization that solicits in the state. (N.H. Admin. R. Jus 404.02(b)(6))
This distinction is particularly important for regional and national nonprofits. An organization may have New Hampshire registration or solicitation obligations without necessarily being subject to the same $500,000 and $2 million financial-statement thresholds that apply to New Hampshire-based organizations.
Organizations operating across state lines should review their registration status and organizational facts with legal counsel or their CPA when determining how New Hampshire’s reporting rules apply.
New Hampshire Law at a Glance
The New Hampshire Department of Justice’s Charitable Trusts Unit administers charitable registration and annual reporting requirements under RSA Chapter 7 and the Jus 400 rules. Registered charitable trusts generally file Form NHCT-12 annually. (N.H. Admin. R. Jus 404.01–404.02)
New Hampshire uses two financial-statement levels for qualifying New Hampshire-based organizations. At $500,000 or more but less than $2 million, the organization must submit a GAAP financial statement; the rule does not require that statement to be a CPA review. At $2 million or more, an audited financial statement is required. (RSA 7:28, III-a–III-b; N.H. Admin. R. Jus 404.02(b)(6))
Because the statutory measurement is revenue, gains, and other support, organizations should evaluate all relevant financial activity annually rather than focusing only on charitable donations. (RSA 7:28, III-a–III-b)
Preparing for a New Hampshire Nonprofit Audit
Organizations approaching the audit threshold should begin preparing several months before fiscal year-end.
Your CPA will typically request:
- General ledger
- Trial balance
- Revenue schedules by source
- Contribution records
- Grant agreements
- Program service revenue reports
- Bank reconciliations
- Board meeting minutes
- Investment statements
- Fixed asset schedules
- Internal control documentation
- IRS Form 990
- Prior-year financial statements
Maintaining complete accounting records throughout the year can help streamline both the audit engagement and the annual NHCT-12 filing process with the Charitable Trusts Unit. (N.H. Admin. R. Jus 404.01–404.04)
Common Reasons New Hampshire Nonprofits Reach the Audit Threshold
Many New Hampshire nonprofits become subject to an audit because of sustained organizational growth across several revenue sources.
Examples include:
- Expansion of healthcare or educational programs
- Growth in program service revenue
- Major capital campaigns
- Large foundation grants
- Increased corporate sponsorships
- Significant end-of-year fundraising
Reviewing projected revenue before the close of the fiscal year allows nonprofit leadership to prepare for audit requirements before reporting deadlines become critical.
Benefits Beyond Compliance
Although New Hampshire requires audited financial statements for qualifying organizations at the statutory threshold, an independent audit can also provide benefits beyond compliance. Audits of nonissuer financial statements are performed under applicable AICPA Statements on Auditing Standards. (RSA 7:28, III-b; AICPA, Statements on Auditing Standards)
A financial statement audit can help your nonprofit:
- Increase donor confidence
- Improve board oversight
- Strengthen internal financial controls
- Enhance grant competitiveness
- Improve financial reporting accuracy
- Demonstrate accountability to regulators
- Support long-term organizational growth
For many organizations, these benefits continue well beyond the annual filing cycle.
Why Choose ELT CPA LLC?
ELT CPA LLC provides independent nonprofit financial statement audit services for charitable organizations throughout New Hampshire.
Our professionals understand nonprofit accounting standards, charitable reporting requirements, and the expectations of the New Hampshire Department of Justice’s Charitable Trusts Unit. We work closely with nonprofit leadership to complete efficient audit engagements while minimizing disruption to daily operations.
Whether your organization is preparing for its first required audit or has undergone annual audits for years, ELT CPA LLC can help you navigate New Hampshire’s nonprofit reporting requirements with confidence.
Frequently Asked Questions
Does New Hampshire use revenue or charitable contributions?
New Hampshire uses revenue, gains, and other support for the statutory financial-statement thresholds, rather than charitable contributions alone. (RSA 7:28, III-a–III-b)
Does every nonprofit operating in New Hampshire have to follow these audit rules?
No. The additional $500,000 and $2 million financial-statement requirements are directed to qualifying New Hampshire-based charitable organizations. Other organizations may still have registration and annual reporting obligations in New Hampshire. (N.H. Admin. R. Jus 404.02(b)(6))
What types of revenue count toward the $2 million threshold?
The statute uses the phrase “revenue, gains, and other support.” Because that measure can include more than contributions alone, organizations should use their financial reporting records and consult their CPA when determining whether the $2 million threshold has been reached. (RSA 7:28, III-b)
Who regulates charitable organizations in New Hampshire?
The New Hampshire Department of Justice’s Charitable Trusts Unit oversees charitable organizations and administers annual reporting requirements. (N.H. DOJ, Charitable Trusts Unit)
Note: A qualifying charitable organization may request an exemption from the additional financial-statement requirement when compliance would constitute a financial burden, subject to the criteria in RSA 7:28, III-c and Jus 404.02(c).
Why Choose Us for CPA Services?
The following qualities make up ELT CPA’s company mission and they are how we stay ahead of the competition. Our mission as a CPA firm is “Putting YOUR needs first”.
Education & Licensure
MS in Accounting, Saint Joseph’s College of Maine
CPA Licensure in New Hampshire and Massachusetts, and able to service client around the United States due to CPA reciprocity
Professional Affiliations
The American Institute of Certified Public Accountants
The Association of Certified Fraud Examiners
Massachusetts Board of Public Accountancy
New Hampshire Certified Public Accountants
References
- New Hampshire RSA 7:28 – Reports by Trustees of Charitable Trusts
https://gc.nh.gov/rsa/html/I/7/7-mrg.htm - New Hampshire Administrative Rules, Jus 404 – Annual Reports of Charitable Trusts
https://gc.nh.gov/rules/state_agencies/jus400.html - New Hampshire Department of Justice – Charitable Trusts Unit
https://www.doj.nh.gov/charitable-trusts - AICPA – Statements on Auditing Standards (Currently Effective)
https://www.aicpa-cima.com/resources/download/aicpa-statements-on-auditing-standards-currently-effective/
