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Audit Preparation

Nonprofit audits in California

California requires an audit once a charity's gross revenue reaches $2 million. Boards often misjudge what counts toward it.

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The threshold

California Government Code §12586(e). Nonprofit Integrity Act

A charitable organisation that receives or accrues gross revenue of $2,000,000 or more in any fiscal year must prepare annual financial statements under GAAP, audited by an independent auditor.

The audited statements must be available for inspection by the Attorney General and by members of the public no later than nine months after the close of the fiscal year.

The exclusion most boards miss

Government grants do not count toward the $2 million threshold where the nonprofit is required to account to the grantor for how the funds were used.

This matters enormously for grant-funded organisations. Total revenue on Form 990 Line 12 is not the same as threshold revenue, and a board reading Line 12 can conclude it has crossed into a mandatory audit when it has not.

It cuts the other way too: if you have been commissioning audits on the strength of Line 12, it is worth checking whether the requirement was ever actually triggered.

What counts as gross revenue

For threshold purposes, gross revenue means total revenue as reported on Form 990 Line 12, including non-cash contributions: in-kind gifts, donated services where recognised, contributed securities.

Then the government grant exclusion above is applied. It is worth doing this calculation deliberately each year rather than assuming last year's answer still holds.

Where an audit is required, the audit itself is performed by an independent audit firm. Wago Pop prepares the organisation for it: a closed and reconciled year, functional expense allocation, grant and net asset schedules, the PBC list, and support through fieldwork.

The audit committee is written into the statute

Gov. Code §12586(e) · California Attorney General guidance

Charities at or above the threshold must have an audit committee appointed by the board. It is not optional and it is not the same thing as the finance committee.

It may consist of a single member, and it may include people who are not board members. It may not include staff, the president or CEO, or the treasurer or CFO.

If a finance committee exists, its members may serve on the audit committee, but they must not constitute 50% or more of it.

The committee recommends retention of the auditor and negotiates the fee, subject to board supervision. In other words, the audit committee is the buyer, not the executive director.

The compliance calendar for a June 30 fiscal year end

June 30 is a common nonprofit year end in California, particularly for organisations tied to the academic calendar.

WhenWhat
July to SeptemberYear-end close, schedules and audit fieldwork. The quieter months, when finance teams have bandwidth.
~15 NovemberForm 990 due. Also RRF-1 to the Attorney General's Registry of Charities, due four months and fifteen days after year end.
31 MarchAudited statements must be publicly available: nine months after year end, under §12586(e).

Which is why preparation belongs in July and August, not October. See the full compliance calendar.

Take this with you

Work out whether your nonprofit actually needs an audit

California's audit trigger is not the number on Form 990 line 12, and the federal Single Audit trigger is a different number again. The worksheet walks both, with the citation beside each step.

  • The California Nonprofit Integrity Act test, and what counts as gross revenue for it
  • The Single Audit test at $1,000,000 of federal awards expended
  • Where a grant agreement can require an audit no statute requires
  • What to do if you cross the line part way through a year

There is no instant download. A person sends it, usually the same working day.

Common questions

Not answered here? Ask us directly: we would rather explain it than have you guess.

Our revenue is under $2 million. Do we need anything at all?

Not under state law, but check three other places before concluding you are clear: your bylaws, which often impose an audit requirement independent of statute; your grant agreements, which frequently require audited statements regardless of size; and your lender, if you have debt. Many smaller organisations opt for a review voluntarily, because funders like to see one and it involves materially less work than an audit.

Do government grants really not count toward the threshold?

Correct, where the organisation is required to account to the grantor for how the funds were used, which is the normal condition of a government grant. This is set out in the Attorney General's own guidance on the Nonprofit Integrity Act. It is genuinely surprising to most boards, and it is worth confirming your own calculation against it rather than relying on Form 990 Line 12.

Can our treasurer sit on the audit committee?

No. The statute specifically excludes the treasurer and CFO, along with staff and the president or CEO. The logic is straightforward: the audit committee oversees the people who prepare the financial statements, so those people cannot sit on it. A single non-excluded board member is sufficient to form a valid committee if that is what your board size allows.

Does Wago Pop perform the audit?

No. The audit is performed by an independent audit firm, which issues the opinion. We get the organisation ready for it and support it through fieldwork: closing the year, building the schedules and PBC list, drafting management's statements and footnote support where appropriate, and answering auditor requests. Because we do not audit, we can also keep your books without an independence conflict. If you have not yet chosen an auditor, we can help the audit committee compare firms.

When should we appoint an auditor?

For a June 30 year end, ideally by May or June. Fieldwork happens July to September, and that window fills up because every June-30 organisation in California wants it. Calendar-year organisations all converge on January and February, with the same effect. Booking early buys you flexibility, and gives preparation time to happen before fieldwork rather than during it.

We have never been audited before. What is the first year like?

Harder than subsequent years, and it is worth budgeting for that. Opening balances have to be verified, accounting policies documented, and the auditor has no prior-year file to lean on. The most useful thing you can do is start assembling the document request early. First-year engagements that run late almost always run late for that reason rather than any other, which is the work we take on.

How do we start?

Book a scoping call using the form on this page, or call us. We will ask who is asking for the audit, when it is due, and what condition your records are in, then tell you what the preparation work involves and what it will cost before anything begins.

Book a scoping call

Twenty minutes, no charge. Tell us what you need and we will tell you what it involves, what it will take, and whether we are the right fit for it.

  • A short call with the person who would actually do the work.
  • A clear scope and a fixed quote before anything begins.
  • We reply to every enquiry within one business day.

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Free resource

Work out whether your nonprofit actually needs an audit

California's audit trigger is not the number on Form 990 line 12, and the federal Single Audit trigger is a different number again. The worksheet walks both, with the citation beside each step.

  • The California Nonprofit Integrity Act test, and what counts as gross revenue for it
  • The Single Audit test at $1,000,000 of federal awards expended
  • Where a grant agreement can require an audit no statute requires
  • What to do if you cross the line part way through a year

There is no instant download. A person sends it, usually the same working day.