Well, that’s no longer the case. With the passage and ongoing implementation of Pennsylvania Act 122, the Commonwealth replaced the decennial cycle with a recurring annual reporting requirement. The legislation originated in the Pennsylvania General Assembly as House Bill 2057 during the 2021–2022 legislative session, and was signed into law by then-Governor Tom Wolf in November 2022. The annual reporting requirement officially went into effect on January 1 of 2025.

The new law brings Pennsylvania in line with modern corporate standards, but it also has some serious implications for the thousands of volunteer-led homeowners and condo associations across the state.

What Act 122 Means for Boards

According to Michael Simone, principal of The Simone Law Firm in Cinnaminson, New Jersey, the annual report required by Act 122 is not an audit, a tax return, or a complex financial disclosure. The Pennsylvania Department of State (DOS) designed the form purely as a corporate health-check to keep public records accurate.

“The state, and Pennsylvania is not the only one, does this to confirm that the entity actually exists,” says Simone. “Further they are trying to confirm who are the current board officers, and also to verify the proper mailing address for the legal entity.  Prior to this, Pennsylvania had no way to confirm any legal entity other than what was originally filed, which in some cases could be quite some time ago.”

Because the vast majority of multifamily communities in the Philly metro area are legally structured as domestic nonprofit corporations, Act 122 applies directly to them. While the state built a temporary cushion into the rollout, that grace period is rapidly expiring. If your board has treated this new filing as a back-burner issue, you could be exposing your community to major operational and legal risks.

For a standard condo or HOA board, the process must be completed online via the Bureau of Corporations and Charitable Organizations portal. According to Simone, the individuals or entities able to file online are board members or hired professionals, including the property manager, attorney or accountant. The filer must search for the association's legal name, verify its PA Entity Number, and provide or confirm the following data points:

• The association's exact legal name and jurisdiction of formation.
• The current registered office address, and principal office address, if different.
• The name of at least one governor, which, in the context of an HOA, translates to an active, seated board member.
• The names and titles of the principal officers, such as President, Secretary, and Treasurer.

For standard for-profit corporations and LLCs, this annual electronic filing carries a modest $7 fee. However, in a rare nod to the volunteer nature of civic organizations, the filing fee for domestic nonprofit corporations is $0. “The State’s intent is not to impose a tax, fee or penalty,” notes Simone, “but just to verify information.”

Navigating the Deadlines

According to Simone, it’s critical that boards do not look at general business news and conflate their deadlines with those of traditional corporations or limited liability companies. The annual deadline for submission is strictly dictated by the entity type under which your association was formed. “In Pennsylvania, there are differing guidelines for LLCs, corporations and non-profits,” Simoe notes. “The nonprofits have a June 30 deadline.”

For the vast majority of community associations registered as nonprofit corporations, the mandatory filing window runs from January 1 through June 30 of each year. This is a permanent recurring deadline—not a one-time event. The significance of 2027 is simply that it is the first year in which full enforcement penalties apply. “Generally corporations, both for-profit and non-profit have until July 1, LLCs until October 1, and any other entities by December 31, if applicable,” says Simone.

If your community is one of the rare exceptions structured as a not-for-profit LLC, your deadline shifts to September 30. If your community operates under an alternative association structure, it could fall on December 31. Managers and board presidents must review their original articles of incorporation immediately to verify their precise entity type. 

“The main circumstance that comes into play is whether they have some type of connected for-profit facility like a banquet hall or a joint commercial property,” Simone notes, “or anything else that might cause a blurring of the entities between profit and non-profit.  It has to do with the legal organization of the ownership entity.”

What Happens in 2027

To ease the Commonwealth into this major bureaucratic shift, Simone notes, “The legislature took the newness of the law into account and created a grace period” for Act 122 compliance. During the 2025 and 2026 calendar years, associations that missed their June 30 deadlines were noted as “delinquent” in the state's public registry, but no punitive administrative actions were taken.

That reprieve disappears as the calendar turns to 2027, however. Under the strict terms of the statute, beginning with the reports due on June 30, 2027, if an association fails to file, the state will issue a notice of non-compliance. If the delinquency is not cured within exactly six months of the original deadline, the state will automatically initiate administrative dissolution or cancellation of the corporate entity. For a board that mistakenly believes a $0 fee means $0 consequence, administrative dissolution will trigger an operational quagmire.

Immediate Operational Gridlock

Title companies and real estate attorneys in the Philadelphia region run exhaustive corporate status checks before closing on any sale. If a unit owner in an administratively dissolved association attempts to sell their condo, the title company will immediately flag the HOA as non-existent. Resale certificates will be rendered legally invalid, mortgage lenders will deny financing, and unit transfers will grind to an immediate halt, tanking neighborhood property values. 

Furthermore, some financial institutions monitor corporate compliance as well, and may flag or restrict the operating and reserve accounts of dissolved entities, potentially stripping the board of its ability to pay vendors or maintain common elements.

Personal Liability Exposure

Incorporation is the legal armor that protects volunteer board members from personal liability when making tough decisions for their community. Administrative dissolution pierces that corporate veil. If the entity is dissolved and a slip-and-fall occurs on a common walkway, or a contract dispute arises with a roofing vendor, the individual board members—and potentially unit owners themselves—could be exposed to direct, personal legal vulnerability. 

Potential Loss of Name Protection

The moment the state administratively dissolves a corporate entity, its legal name is released into the public domain and becomes available for any other filing association to claim. If your community is known as the ‘Whispering Woods Homeowners Association,’ any third-party business entity, disgruntled resident, or developer can legally sweep in, pay a fee, and register that exact name. If that happens before you reinstate, your community permanently loses the exclusive right to its own identity and will be forced to undergo a costly, legally exhaustive renaming process. If no other entity claims the name during the dissolution window, reinstatement restores it — but that window of vulnerability is real and uncontrolled. 

A Checklist for Proactive Management

Act 122 specifically dictates that a lack of direct notice from the Department of State will not be accepted as an excuse for missing a deadline—so boards must be proactive. 

To safeguard your community before the 2027 enforcement axe falls,your board should implement the following protocols immediately:

• Update Your Registered Address: The state sends warning postcards two months prior to the June 30 deadline. If your association's registered corporate address is still listed as the original developer's office from 15 years ago, or the kitchen table of a board president who moved away years ago, you will never receive the warning. File a Change of Registered Office form to ensure mail routes to your current management company or active board secretary.

Act 122 has permanently changed the landscape of community association governance in Pennsylvania. In a world where a $0 filing can cost you your legal identity, vigilance is no longer optional—it is a fiduciary requirement.