POST-AWARD COMPLIANCE CHECKLIST

Ohio Community Reinvestment Area (CRA) Tax Abatement: Compliance Requirements

What you must do after you win this award — administered by Local Municipality / Ohio Department of Development · Ohio.

8
Total requirements
4
Clawback-risk items
8
Deadline-bound

⚠ Common Disallowed-Cost Pitfalls

  • Financial & Cost Eligibility: Ohio Department of Development will not review materials until fee is received; abatement may be void if not paid
  • Reporting: Abatement may be rescinded if job/payroll performance falls below 50% of projections for 2 consecutive years
  • Ongoing Eligibility: Tax delinquency may result in immediate termination of the exemption and clawback of abated taxes
  • Ongoing Eligibility: Starting work before agreement execution will render the exemption void; no retroactive abatement available
  • Reporting: Failure to file annual reports may result in loss of CRA designation or inability to grant new exemptions
  • Other Obligations: Municipality may terminate exemption if property is not properly maintained or has code violations
  • Financial & Cost Eligibility: Municipality may be liable to school district for unpaid compensation; may affect future CRA approvals
  • Other Obligations: Transfer without approval may void the abatement and trigger clawback of previously abated taxes

Reporting

  • Clawback riskAnnual

    Commercial and industrial project owners must submit annual job creation and payroll performance reports as specified in the CRA Agreement to the Tax Incentive Review Council.

    Deadline: as specified in the individual CRA agreement

    Source: ORC 3735.69; local CRA agreements

  • HighAnnual

    Municipality or county must submit an annual status report to the Ohio Department of Development summarizing all activities and projects granted a tax exemption within the CRA.

    Deadline: on or before March 31 each year

    Source: ORC 3735.69(B); ORC 3735.672

Financial & Cost Eligibility

  • Clawback riskOne Time

    Commercial and industrial project owners must pay a state application fee of $750 within 15 days of passage of local legislation approving the CRA agreement.

    Deadline: within 15 days of passage of local legislation

    Source: ORC 3735.672(C); CRA Procedures guidance

  • HighAnnual

    If project generates $2 million or more in new annual payroll, municipality must share 50% of excess municipal income tax revenue with the school district unless a different revenue sharing agreement is negotiated.

    Deadline: annually based on income tax collections

    Source: ORC 5709.82(C) and (D) as amended by SB 33

Ongoing Eligibility

  • Clawback riskOngoing

    Property owner must remain current on all pre-improvement property taxes throughout the entire abatement period.

    Deadline: continuously throughout the abatement term

    Source: Local CRA agreements; common municipal practice

  • Clawback riskOne Time

    Commercial and industrial project owners must not commence construction or improvements until a written CRA agreement is fully executed and approved by local legislative authority.

    Deadline: before any construction, demolition, or site preparation begins

    Source: ORC 3735.671; local CRA procedures

Other Obligations

  • HighOngoing

    Property must be free of code violations and comply with all zoning regulations throughout the abatement period.

    Deadline: continuously throughout the abatement term

    Source: Local CRA ordinances and agreements

  • HighEvent Driven

    Property owner must obtain written approval from the municipality before selling or transferring the property during the abatement term; new owner assumes all agreement obligations.

    Deadline: before any sale or transfer is completed

    Source: Local CRA agreements (e.g., Toledo CRA procedures)

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This checklist is compiled from official program sources and general grant-management rules for informational purposes. Final compliance obligations are governed by your specific grant agreement and the administering agency — always verify with Local Municipality / Ohio Department of Development.