Receiving a warning that your charity’s annual return is overdue can feel alarming - particularly if you are a volunteer who has inherited the treasurer role or discovered that something was missed before you arrived.
Don't panic! An overdue notice does mean your charity has fallen behind on one of its legal obligations. But it is also an opportunity to contact Charities Services, explain what has happened and make a clear plan to put things right.
The thing not to do is ignore it and hope someone else will eventually take care of it.
In this guide:
Every registered charity in Aotearoa New Zealand must file an annual return within six months of its balance date—the end of its financial year.
Filing usually involves:
For most small charities, this means preparing a Tier 3 or Tier 4 Performance Report and including it with the annual return.
Your charity might have missed the deadline because:
Whatever the reason, your next step is the same: work out what is missing and start talking to Charities Services.
An overdue warning does not usually mean your charity is about to be deregistered immediately.
However, failing to file an annual return can put your registration at risk. Charities Services says that repeated incomplete returns can lead to deregistration, and clear non-compliance can include failing to file annual returns for two or more years.
Deregistration creates considerably more work than dealing with the overdue return.
A deregistered organisation can no longer describe itself as a registered charity or claim charitable tax exemptions. It may lose access to funding that is only available to organisations on the Charities Register. An incorporated society may also need to resume filing annual returns with the Companies Office.
Registered charities are generally exempt from income tax. Once deregistered, an organisation will generally become liable for income tax unless it qualifies for another exemption. It may also face tax consequences relating to its accumulated assets.
You may still need to prepare the missing financial information before you can reregister, so ignoring the problem rarely saves any work.
In other words: don’t panic, but do take action.
Before contacting Charities Services, spend a short amount of time understanding the problem.
You do not need to solve everything immediately. At this stage, you are simply trying to answer a few basic questions:
For a straightforward situation, this might take five to thirty minutes.
You might discover that everything has already been prepared and someone simply forgot to press submit. At the other end of the scale, you might find several years of incomplete records and nobody who knows how the previous reports were prepared.
If you cannot answer the basic questions within half an hour, that is useful information in itself. It suggests that resolving the return may require a more substantial piece of work—and that you should be realistic about the time and support you will need.
Once you have a basic understanding of the situation, contact Charities Services.
You do not need to wait until you have fixed everything.
Charities Services encourages charities to get in touch with questions or concerns. You can contact them at [email protected] or call 0508 CHARITIES (0508 242 748). Explain:
Depending on the situation, you may want to ask for one or more of the following.
Ask whether Charities Services can give you additional time to complete the return. Try to propose a realistic date rather than asking for an open-ended extension. For example:
We recently changed treasurers and discovered that our annual return has not been filed. We have now located the organisation’s financial records and expect to prepare and submit the return within four weeks. Could we please have an extension until 30 September?
If you do not yet know how long the work will take, be honest about that. Explain what you are doing next and when you will update them. For example:
We have only just become aware that the return is overdue. I have arranged a meeting with our chair and previous treasurer this week to establish what financial records are available. I will contact you again by Friday with a proposed filing date.
Ask for help if you do not understand the notice or are unsure what you need to file.
You might have submitted an annual return but not attached the required Performance Report. You may have started a return without completing it, selected the wrong reporting tier, or believed that another officer had filed it.
It is much better to ask a direct question than to spend days trying to guess what has gone wrong.
Tell Charities Services how you intend to resolve the problem and check that your proposed approach makes sense.
A clear plan shows that your organisation is taking the issue seriously—even if the work itself cannot be completed immediately.
Getting an extension is helpful, but an extension does not prepare the return for you. Write down the actual steps required, who will complete each one and when it will happen. Your plan may include:
Breaking the work into smaller jobs makes it much easier to see what can be completed internally and where you need help.
For help understanding Tier 4 reporting, see: What is Tier 4 Reporting, Why Is It Required, and How Do I Do It?
An overdue annual return is often not just a financial reporting problem. It can also reveal gaps in your organisation’s systems.
Start by finding out where the information is held. This might include:
You should also identify who can give you access.
The current chair, secretary or treasurer may not hold everything. You might need to contact a previous officer, bookkeeper, accountant or another person who helped prepare earlier returns.
Where possible, avoid building the whole solution around one person. Make sure the organisation itself has ongoing access to its bank records, reporting files and online accounts.
You do not have to solve the problem alone. Support might come from:
At Good Numbers, we like to say that the treasurer is the spokesperson for the money, not the person solely responsible for it. Financial reporting is a responsibility held by the organisation and its governing group, not something one volunteer should be left to carry by themselves.
If you are the treasurer, ask your chair or another trustee to work alongside you. They may be able to track down information, speak to previous officers, approve spending on professional help or simply make sure the plan keeps moving.
Once you have told Charities Services what you are going to do, follow through on it.
Put the agreed filing date in your calendar. Set reminders before the deadline. Schedule the necessary meetings and ask other people for information promptly.
If you later realise the work will take longer than expected, contact Charities Services before the new deadline passes.
A short update is far better than going silent:
We are continuing to work on the overdue return, but locating records from the previous treasurer has taken longer than expected. We have now received the bank statements and expect to complete the Performance Report within another two weeks. Could you please confirm whether a further extension is possible?
The aim is to show that your charity is actively working to meet its obligations—not ignoring the problem.
After the overdue return has been filed, take a little time to improve the process for next year.
That could mean:
The annual return is due six months after your balance date, but preparing for it should not begin six months after the year has ended.
The more organised your records are during the year, the easier the filing process will be.
If missing or disorganised financial records are the main reason your return is overdue, Good Numbers may be able to help.
The Good Numbers app can be used with historical transactions to help small charities rebuild previous years’ financial information and prepare their reporting. It can then continue keeping the organisation’s finances up to date, so next year’s return is much easier. Learn more about the Good Numbers app.
Or, if your organisation is ready to get started: Sign up for the Good Numbers app
This guide provides general information for small charities and non-profits in Aotearoa New Zealand. Your organisation’s circumstances may be different. Contact Charities Services or a suitably qualified adviser if you are unsure about your legal or reporting obligations.
Ask Duncan anything — big or small. He’ll get back to you ASAP, and your questions will help improve the information here for everyone.
