Ernest L. Tomkiewicz CPA LLC
New Hampshire Nonprofit Financial Review
Understand when New Hampshire charitable organizations need an independent CPA financial review and how ELT CPA LLC can help you meet state reporting requirements.








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As charitable organizations grow, their financial reporting responsibilities often become more extensive. New Hampshire uses a revenue-based framework for certain New Hampshire-based charitable organizations, with additional financial statement requirements beginning at $500,000 in revenue, gains, and other support.
Under RSA 7:28, a charitable organization with $500,000 or more in revenue, gains, and other support that is required to file Form 990 with the Attorney General must submit its latest financial statement prepared in accordance with generally accepted accounting principles (GAAP). Once the organization reaches $2,000,000 or more, an audited GAAP financial statement is required. (RSA 7:28).
New Hampshire administrative rules further describe the filing requirement for New Hampshire-based organizations and state that private foundations are not subject to this particular financial statement requirement. The rules do not state that organizations in the $500,000-to-under-$2,000,000 range must obtain an independent CPA review; they require a GAAP financial statement. (N.H. Admin. Code Jus 404.02).
This distinction matters. A CPA review is a professional assurance engagement under AICPA standards, but current New Hampshire law does not make a CPA review the mandatory service for organizations in this revenue band. An organization may still choose a review when it wants limited assurance, when a lender or grantor requests one, or when its board believes additional independent oversight is appropriate.
Whether your nonprofit serves Concord, Manchester, Nashua, Portsmouth, Keene, Dover, Laconia, or communities throughout New Hampshire, planning ahead for annual reporting can reduce filing delays and help the board determine whether a GAAP financial statement, voluntary CPA review, or audit best fits the organization.
New Hampshire Financial Review Requirements at a Glance
| Requirement | Details |
| State | New Hampshire |
| Revenue Trigger | At least $500,000 but less than $2,000,000 in gross revenue |
| Required Financial Service | Independent Financial Statement Review |
| Next Reporting Threshold | $2,000,000 or more in gross revenue generally requires an independent financial statement audit |
| Who This Applies To | Charitable organizations headquartered or principally located in New Hampshire |
| Required Professional | Independent Certified Public Accountant (CPA) |
| Governing Authority | RSA 7:28 |
| Administering Agency | New Hampshire Department of Justice – Charitable Trusts Unit |
Quick Answer
If your organization is subject to New Hampshire’s charitable trust annual reporting rules and has $500,000 or more but less than $2,000,000 in revenue, gains, and other support, it generally must submit its latest GAAP financial statement. Current law does not specifically require that statement to be reviewed by an independent CPA. At $2,000,000 or more, an audited financial statement is generally required. (RSA 7:28).
When Is a Financial Review Required in New Hampshire?
For this specific charitable reporting threshold, New Hampshire does not expressly require a CPA review. That is an important correction to the way this requirement is sometimes summarized.
RSA 7:28 requires a GAAP financial statement beginning at $500,000 and an audited GAAP financial statement beginning at $2,000,000. The administrative rule similarly requires a GAAP financial statement for qualifying New Hampshire-based organizations in the lower band and an audit at the higher threshold. (RSA 7:28). (Jus 404.02).
A nonprofit may nevertheless elect to obtain a CPA review. That can be useful when a board, lender, grantmaker, or other stakeholder wants independent limited assurance without the scope and cost of a full audit.
What Is a Financial Statement Review?
A financial statement review is an accounting service performed by an independent Certified Public Accountant under the Statements on Standards for Accounting and Review Services (SSARS) issued by the AICPA. A review primarily involves analytical procedures and inquiries of management and provides limited assurance rather than the reasonable assurance associated with an audit. (AICPA Preparation, Compilation, and Review Standards).
For a New Hampshire organization in the $500,000-to-under-$2,000,000 band, a review may be a voluntary governance or stakeholder decision rather than a statutory requirement under RSA 7:28.
New Hampshire Law at a Glance
New Hampshire is distinctive because its charitable reporting rule is based on revenue, gains, and other support and because the administrative rules focus the additional financial statement requirement on New Hampshire-based organizations. Private foundations are excluded from this specific rule.
The law also creates a clear audit threshold at $2 million. Below that level, the key statutory requirement is that the submitted financial statement be prepared in accordance with GAAP – not that it carry a CPA review report.
Financial Statement, CPA Review, and Audit
GAAP Financial Statement
For qualifying New Hampshire-based organizations in the lower revenue band, the state requires a financial statement prepared in accordance with generally accepted accounting principles.
CPA Review
A CPA review is an optional assurance engagement unless another contract, grant, lender, governing document, or stakeholder requirement makes it necessary.
- Analytical procedures
- Inquiries of management
- Limited assurance
- Less extensive than an audit
Financial Audit
- Detailed testing of financial records
- Confirmation and other audit procedures
- Evaluation of relevant internal controls
- Reasonable assurance
- Generally required under RSA 7:28 once revenue, gains, and other support reach $2,000,000 or more
Preparing for Your Financial Reporting Requirement
Whether your organization prepares GAAP financial statements internally, engages a CPA for a review, or is approaching the audit threshold, organized records can make the process more efficient. Commonly needed records include:
- Statement of Financial Position
- Statement of Activities
- General ledger
- Trial balance
- Bank reconciliations
- Revenue schedules
- Grant documentation
- Board meeting minutes
- Investment schedules
- Significant contracts
- IRS Form 990
Organizations nearing the $2 million audit threshold should plan early because an audit generally requires more lead time, documentation, and coordination than preparation of unaudited GAAP financial statements.
Benefits Beyond Compliance
Even when a CPA review is not required by New Hampshire law, some organizations choose one because independent limited assurance can support:
- Donor and grantmaker confidence
- Board oversight
- Financial transparency
- Loan or financing requests
- Internal accounting improvements
- Readiness for a future audit
Why Choose ELT CPA LLC?
ELT CPA LLC works with nonprofit organizations throughout New Hampshire on financial statement reviews, audits, and nonprofit accounting matters.
Our team can help organizations understand the difference between the state’s GAAP financial statement requirement and a formal CPA review, determine what level of service is appropriate, and prepare for an audit when the statutory threshold is reached.
Our services include:
- Independent financial statement reviews
- Nonprofit financial statement audits
- Nonprofit accounting guidance
- GAAP financial statement assistance
- Annual reporting support
- Remote service throughout New Hampshire
- Responsive communication throughout the engagement
Frequently Asked Questions
Does New Hampshire require a CPA review at $500,000?
Not under the current charitable reporting statute. RSA 7:28 requires the latest financial statement prepared in accordance with GAAP beginning at $500,000, but it does not expressly require an independent CPA review in the $500,000-to-under-$2,000,000 range.
When is an audit required?
Organizations subject to the rule generally must submit an audited GAAP financial statement once revenue, gains, and other support reach $2,000,000 or more.
Do these requirements apply to every charity registered in New Hampshire?
No. The administrative rules describe this financial statement requirement for New Hampshire-based organizations and exclude private foundations from this specific provision.
Can our organization still choose a CPA review?
Yes. A voluntary review may be useful when the board, a lender, a funder, or another stakeholder wants independent limited assurance even though state law does not expressly require a review.
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 Revised Statutes Annotated (RSA) 7:28 – Reports by Trustees of Charitable Trusts
https://gc.nh.gov/rsa/html/I/7/7-mrg.htm
- New Hampshire Code of Administrative Rules – Jus 404.02, Form NHCT-12 Annual Report
https://gc.nh.gov/rules/state_agencies/jus400.html
- New Hampshire Department of Justice – Charitable Trusts Unit
https://www.doj.nh.gov/bureaus/charitable-trusts
- American Institute of Certified Public Accountants (AICPA) – Preparation, Compilation, and Review Standards
https://www.aicpa-cima.com/resources/landing/preparation-compilation-and-review-standards
