Compliance calendar¶
Status: Draft, pre-formation. Dates assume the Ganjier Guild incorporates by December 31, 2026 with a fiscal year that runs January 1 – December 31. If the Guild is incorporated in a short first fiscal year, several deadlines shift; recompute on the date the formation ADR is ratified.
This calendar is the working operational compliance tracker. It covers federal tax, state nonprofit registration, lobbying disclosure, internal governance, and information-security obligations. Each row references the controlling authority so counsel can verify.
Disclaimer. This is not legal or tax advice. Confirm every date and amount with the Guild's tax counsel and registered agent in the state of incorporation before relying on it.
How to read this file¶
- Dates are absolute (e.g.,
May 15, 2027) wherever a fixed deadline applies, and relative (e.g.,T+30 days from incorporation) when the deadline depends on an event. - Owner is the role responsible for the action, not a person, so the calendar survives turnover.
- Cadence indicates one-time, annual, biennial, or rolling.
Federal — IRS¶
| Date | Item | Owner | Cadence | Authority |
|---|---|---|---|---|
| T+0 (formation) | File state Articles of Incorporation; obtain certified copy | Administrator + counsel | Once | State nonprofit corporation act |
| T+0 to T+30 days | Apply for EIN via SS-4 (online) | Treasurer | Once | IRC §6109 |
| T+27 months (deadline to file 1024) | File Form 1024 for 501©(6) recognition with $600 user fee via Pay.gov | Treasurer + counsel | Once | Rev. Proc. 2024-5; Form 1024 instructions |
| May 15, 2028 (Year 1) and May 15 annually thereafter | File Form 990 (or 990-EZ / 990-N postcard depending on gross receipts) for prior fiscal year | Treasurer + auditor | Annual | IRC §6033; Form 990 instructions |
| Within 30 days of the 990 filing | Post the latest Form 990 publicly (e.g., on the Guild website) and retain three years of returns for public inspection | Communications | Annual | IRC §6104(d); Treas. Reg. §301.6104(d)-1 |
| With each 990 | Provide IRC §6033(e) notice of nondeductible-dues percentage to all members on dues invoices | Treasurer | Annual | IRC §6033(e); §162(e) |
| If lobbying nondeductible % is unreasonably underestimated | File and pay Form 990-T proxy tax as a fallback (avoid by accurate notices) | Treasurer | As needed | IRC §6033(e)(2) |
| If unrelated business income > $1,000 | File Form 990-T | Treasurer | Annual when applicable | IRC §511; §6012 |
| Quarterly (Apr 15 / Jun 15 / Sep 15 / Jan 15) | Estimated tax on UBIT, if any | Treasurer | Quarterly when applicable | IRC §6655 |
| As employees are hired | File Form 941 quarterly; Form W-2/W-3 by Jan 31; Form 940 by Jan 31 | Treasurer / payroll | Recurring | IRC §3402, §3306 |
| As contractors paid ≥ $600/yr | Issue Form 1099-NEC by Jan 31 — see finance/1099-process.md for full SOP | Treasurer | Annual | IRC §6041A |
Federal — Lobbying disclosure¶
The proposal contemplates an issue-advocacy program but no registered federal lobbying in Year 1. If the Guild later employs anyone whose lobbying activities exceed thresholds:
| Trigger | Item | Authority |
|---|---|---|
| Employee spends ≥ 20% of time on lobbying contacts and the Guild crosses the quarterly expenditure threshold (currently $14,000) | Register under the Lobbying Disclosure Act within 45 days; file LD-1 | 2 U.S.C. §1601 et seq. |
| Each calendar quarter after registration | File LD-2 disclosure | 2 U.S.C. §1604 |
| Twice per year | File LD-203 semiannual contributions report | 2 U.S.C. §1604(d) |
If the Guild engages outside lobbying counsel under contract, the firm typically files; the Guild still owes accurate §6033(e) member notices regardless.
State — Maine path (if Maine is selected)¶
| Date | Item | Owner | Cadence | Authority |
|---|---|---|---|---|
| T+0 | File Articles of Incorporation, $40 fee | Counsel + administrator | Once | Maine Title 13-B |
| T+30 days | Appoint registered agent and confirm consent on file | Administrator | Once | Title 13-B §304 |
| June 1 each year | File annual report with Maine Secretary of State, $35 fee | Administrator | Annual | Title 13-B §1301 |
| Before solicitation | Register under Maine Charitable Solicitations Act if soliciting contributions (501©(6) trade associations are generally exempt from charitable-solicitation registration but confirm) | Treasurer + counsel | Once if applicable | 9 M.R.S. §5001 et seq. |
State — Minnesota path (if Minnesota is selected)¶
| Date | Item | Owner | Cadence | Authority |
|---|---|---|---|---|
| T+0 | File Articles of Incorporation, $70 by mail or $90 online | Counsel + administrator | Once | Minn. Stat. ch. 317A |
| T+0 | Appoint registered agent | Administrator | Once | §317A.121 |
| December 31 each year | File annual renewal with Minnesota Secretary of State, no fee for nonprofit (corporation is dissolved administratively if missed) | Administrator | Annual | §317A.823 |
| Before solicitation | Register under MN charitable-solicitation rules if applicable (trade associations generally exempt; confirm) | Treasurer + counsel | Once if applicable | Minn. Stat. ch. 309 |
Other state registrations (as the Guild grows)¶
| Trigger | Item | Cadence |
|---|---|---|
| Hiring an employee in any state | Register for state withholding, unemployment insurance, and workers' comp where required | Per state |
| Holding an in-person event in a state | Confirm whether the state treats the activity as "doing business" requiring foreign-entity registration | Per event |
| Soliciting contributions in a state | Charitable-solicitation registration where applicable (Unified Registration Statement covers many) | Annual where required |
| Sales of goods or taxable services | State sales/use tax registration | Per state |
Internal governance — annual cycle¶
| Month | Item | Owner |
|---|---|---|
| January | Board adopts annual calendar; confirm officers; review insurance (D&O, GL, cyber) | Secretary |
| January | All directors and officers re-sign Conflict of Interest disclosures; conflicts log updated | Secretary |
| January | All directors and key staff re-acknowledge Code of Ethics and Whistleblower policy | Secretary |
| February | Audit or financial review committee meets; engages auditor or reviewer | Audit chair |
| March | Audit/review begins for prior fiscal year | Treasurer + auditor |
| April | Draft Form 990 ready for board review | Treasurer |
| May | Board reviews and approves Form 990 before filing; file by May 15 | Board |
| June | Mid-year financial review against budget; member dues renewal cycle audit | Treasurer |
| July | Strategic planning cycle begins for next fiscal year | Board chair |
| August | Committee charters reviewed; volunteer rosters refreshed | Committee chairs |
| September | Draft next-year budget circulated; dues schedule reviewed | Treasurer |
| October | Board approves next-year budget and dues; Nominating committee opens slate process | Board |
| November | Member ballot for board seats and any bylaws amendments | Secretary |
| December | Board self-assessment; document retention review under retention policy; annual policy refresh | Board chair |
Policies — review and reaffirmation¶
Per governance/policies/, each board member and key staff member reaffirms in writing each January:
- Conflict of Interest
- Code of Ethics
- Code of Conduct (online)
- Whistleblower
- Document Retention
- Gift Acceptance
Each policy itself is reviewed by the Board no less than every two years, or sooner if law or operations change materially.
The Finance Committee additionally reviews these policies annually before fiscal-year-end and recommends updates to the board:
- Reimbursement Policy / Accountable Plan
- 1099 Process
- Complimentary Membership Policy
- Scholarship & Hardship Waiver
- Hours Certification
- Benefits-Aware Volunteering
Information security and data¶
| Cadence | Item | Owner |
|---|---|---|
| Continuous | Member PII never committed to this repository (see SECURITY.md) | All contributors |
| Quarterly | Joint access review against the systems inventory (sysadmin + at least one non-sysadmin director); two-page report to board consent agenda — see Administrator: IT and systems administration | Sysadmin + Treasurer (or designated tech director) |
| Annually | Comprehensive access review for member portal, payment processor, email platform, hosting, and DNS | IT lead |
| Annually | Backup-restoration test for member database and finance records | IT lead |
| Annually | Cybersecurity policy review and tabletop incident drill | IT lead + Board |
| Annually (January) | Break-glass tabletop drill: emergency credential envelope refresh, secondary administrator confirmation, recovery procedure walkthrough | Sysadmin + secondary administrator + Board Chair |
| On incident | Incident response per SECURITY.md; notify counsel; notify affected members per applicable state breach laws | IT lead + counsel |
Insurance — annual review¶
| Coverage | Trigger |
|---|---|
| Directors & Officers (D&O) | Required from formation |
| General Liability | Required before any in-person event |
| Cyber liability | Required once the Guild stores member PII or processes payments |
| Event-specific | Per event, per venue contract |
Quick reference — first 12 months from incorporation¶
- T+0: Articles filed; registered agent confirmed; bylaws adopted by initial board
- T+0 to T+30: EIN obtained; bank account opened; D&O insurance bound; conflict-of-interest disclosures signed
- T+30 to T+90: Form 1024 prepared and filed; member portal soft-launched; founding member roster opens
- T+90 to T+180: First member dues processed; first sponsor agreements signed; first quarterly board meeting; §6033(e) notice methodology approved
- T+180 to T+365: First in-person convening; audit committee engaged; year-end close planned; budget for Year 2 approved
Sources to verify before publishing as adopted:
- IRC §6033, §6033(e), §6104(d), §501©(6), §513(i), §511, §162(e)
- Treas. Reg. §301.6104(d)-1
- Form 990 / 990-T / 1024 instructions (current revisions)
- Lobbying Disclosure Act, 2 U.S.C. §1601 et seq.
- Maine Title 13-B (Maine Nonprofit Corporation Act); Maine Sec'y of State filing fee schedule
- Minnesota Stat. ch. 317A; MN Sec'y of State filing fee schedule
- State charitable-solicitation statutes where the Guild fundraises