For nonprofits assigned to the 2026 filing cycle, the biennial report deadline has passed. A missed report can surface during a grant application, lease renewal, contract review, or request for proof of active status.
Kevin D. Judd, Esq., is a board director and registered parliamentarian who provides board governance legal services for nonprofit corporate structures. From a governance perspective, the filing is more than an administrative task. It’s part of the board’s responsibility to maintain accurate organizational records and preserve the corporation’s active status.
Confirm Your Nonprofit’s Filing Cycle
A nonprofit’s first D.C. Biennial Report, Form BRA-25, is due by April 1 of the calendar year after it forms or registers in the District. Reports are then due every two years, placing each organization on an odd-numbered or even-numbered filing cycle.
The Corporations Division of the D.C. Department of Licensing and Consumer Protection (DLCP) maintains an online business filings search. Board members and administrators should use it to check the organization’s current status, filing history, and most recent report. Compare those records with the nonprofit’s internal compliance calendar rather than relying on a former officer’s recollection or an old reminder.
Organizations on the 2026 cycle should prioritize any missing report. An active listing doesn’t confirm that every required report has been filed. The board should also verify that its registered agent information is current.
Prepare & File Form BRA-25
Nonprofits file Form BRA-25 through the DLCP Corporations Division’s BOSS portal, the agency’s online system for business and entity registrations. Online filings are generally processed within five business days.
As of November 4, 2026, the report fee is $80, with a $50 penalty for filing after the deadline. DLCP offers three-day expedited processing for an additional $50 and next-business-day processing for an additional $100. Expedited service may matter when an organization needs a completed filing before requesting a certificate of good standing.
Before submitting the report, review the organization’s current information and assign one person to complete the filing. The board or an authorized officer should retain the submission confirmation and completed report with its governance records. This file documents who submitted the report, what information it contained, and when it was filed.
Include the District’s Beneficial Ownership Disclosure
Beneficial ownership information is required in the District’s filing process, including for nonprofits. The requirement covers people with a direct or indirect ownership or governance interest exceeding 10 percent. It also covers people who control financial or operational decisions despite holding an interest of 10 percent or less.
Since January 1, 2020, District formation filings and biennial reports have required this disclosure. The report must provide each identified person’s name, home address, and business address. Before preparing the filing, a nonprofit should identify the people with meaningful governance authority or control over significant financial and operational decisions.
This District disclosure is separate from federal FinCEN beneficial ownership reporting. Whether an organization has a federal FinCEN filing obligation doesn’t determine whether its D.C. report requires beneficial ownership information. The District applies its own disclosure rules and filing system.
Address a Late or Revoked Filing Status
A late filing should be addressed before it affects the organization’s status. If a nonprofit doesn’t file within five months of the deadline, the Mayor may begin administrative dissolution proceedings, and after notice and a cure period, the organization’s corporate status is revoked and it’s no longer authorized to do business in the District. Administrative revocation can raise difficult questions about grant agreements, leases, contracts, and other commitments that assume the organization is active.
First, check the current DLCP status and identify every outstanding report. Obtaining a certificate of good standing requires the most recent biennial report and payment of all applicable fees and penalties.
Reinstatement after revocation requires Form GN-5, the application for reinstatement, along with all past-due reports, filing fees, and late penalties. Boards should collect the organization’s filing history and current records before making representations to a funder, landlord, or contracting party about its status.
Make Biennial Filing Part of Board Governance
Filing the report and maintaining a registered agent are ongoing obligations for an active District nonprofit. Boards reduce the risk of missed deadlines by adding the filing cycle to an annual compliance calendar, assigning responsibility for monitoring the DLCP record, and documenting the review and submission in board materials.
Useful records to maintain include:
- The DLCP filing confirmation and a copy of each submitted Form BRA-25.
- A current list of officers, directors, registered agent information, and people whose authority may require beneficial ownership disclosure.
- Board minutes identifying who’s responsible for recurring corporate compliance tasks.
These records allow a board to respond confidently when a grantmaker, lender, government agency, or contracting party requests a certificate of good standing. They also give incoming directors and officers a workable record of the organization’s responsibilities instead of leaving critical dates to informal handoffs.
Our Non-Profit Law and Board Governance services address disclosure requirements, fiduciary duties, governance documents, board accountability, and nonprofit tax filing matters. For guidance on nonprofit governance and compliance, contact Law Firm of Kevin D. Judd at (202) 888-8454.