Some years back I was looking into forming a non-profit to do some donation-funded environmental cleanup (not huge - probably on the order of a few tens of thousands of dollars a year). What I learned is that while SOX doesn't apply to non-profits, there are similar SOX-inspired rules that do. The advice from everyone I talked to at various non-profits about how to get set up: Just drop it. The regs require so much paperwork and oversight that it would easily cost 10x that much in compliance and auditing. If you aren't making a BIG non-profit, it's not worth the trouble any more, the overhead will crush you.