TLDR
Form 990 is the IRS annual information return for tax-exempt organizations. Which version an organization files — 990, 990-EZ, or 990-N — depends on gross receipts and total assets. The due date is the 15th day of the 5th month after fiscal year end (May 15 for calendar-year filers), with an automatic 6-month extension available by filing Form 8868. Schedule B donor disclosure was significantly changed by Revenue Procedure 2018-38 and subsequent litigation; the current rule exempts most 501(c)(3) public charities from disclosing donor identifying information to the public, but the requirements remain on the IRS copy.
Form 990 Filing: Complete 2026 Nonprofit Guide
Form 990 is the primary tool the IRS uses to maintain oversight of tax-exempt organizations, and it is a public document. Every grant funder, major donor, journalist, and watchdog organization can read it. The figures on the 990, the compensation disclosures in Part VII, the schedule of contributors in Schedule B, and the program service descriptions in Part III are all visible. Getting them right is not optional.
Which form applies
The three versions of Form 990 are differentiated by gross receipts and total assets:
| Scenario | Required Form |
|---|---|
| Gross receipts ≥ $200,000 OR total assets ≥ $500,000 | Full Form 990 |
| Gross receipts < $200,000 AND total assets < $500,000 | Form 990-EZ (optional upgrade to 990) |
| Gross receipts normally ≤ $50,000 | Form 990-N (e-Postcard) |
| Private foundation (any size) | Form 990-PF |
“Gross receipts” is defined as the organization’s total income from all sources before deducting expenses. “Normally” for 990-N purposes means an average of $50,000 or less over the most recent three years.
An organization eligible for 990-EZ or 990-N may always choose to file the longer form. Organizations that have historically filed the full 990 and want to step down to 990-EZ must meet the gross receipts and total assets thresholds in the relevant year.
Due date and extension
Form 990 is due on the 15th day of the 5th month after the fiscal year end:
| Fiscal Year End | Form 990 Due | Extended Due Date |
|---|---|---|
| December 31 | May 15 | November 15 |
| March 31 | August 15 | February 15 |
| June 30 | November 15 | May 15 |
| September 30 | February 15 | August 15 |
The automatic 6-month extension is obtained by filing Form 8868 on or before the original due date. No reason is required. The extension is automatic, not discretionary — if Form 8868 is properly filed on time, the extension is granted.
Important: The extension must be filed before the original due date. There is no provision for a retroactive extension if the original deadline is missed.
Required schedules for mid-sized nonprofits
| Schedule | Requirement Trigger |
|---|---|
| Schedule A | Required for all 501(c)(3) public charities |
| Schedule B | Contributors of $5,000 or more during the year |
| Schedule C | Political campaign or lobbying activities above thresholds |
| Schedule D | Restricted funds, endowments, investments, credit counseling |
| Schedule F | Activities outside the U.S. above $10,000 threshold |
| Schedule G | Fundraising events or gaming with gross receipts over $15,000 |
| Schedule I | Grants to U.S. organizations or individuals over $5,000 |
| Schedule J | Compensation over $150,000 for certain individuals |
| Schedule L | Transactions with interested persons (related parties) |
| Schedule N | Liquidation, termination, dissolution |
| Schedule O | Supplemental information required for various questions |
Form 990 Part IV includes a checklist for all schedules. Working through Part IV line by line early in the preparation process identifies which schedules are needed and prevents last-minute scrambles.
Schedule B: the donor disclosure that software still gets wrong
Schedule B (Schedule of Contributors) requires listing donors who contributed $5,000 or more during the fiscal year. The IRS requires names, addresses, and contribution amounts on the copy filed with the IRS. The publicly available copy has different rules.
Revenue Procedure 2018-38 generally exempted most tax-exempt organizations (other than 501(c)(3) public charities whose Schedule B is required as a condition of maintaining public charity status) from disclosing donor identifying information on the publicly-disclosed copy. 501(c)(3) public charities that file Schedule B as a public document must still include it, but may redact donor names and addresses on the public copy while keeping full information on the IRS copy.
The software problem: Many tax preparation platforms default to using the same Schedule B version for both the IRS filing and the public copy, either over-disclosing or under-disclosing depending on the default. Organizations should confirm with their preparer that the correct version is being used for each purpose.
Part VII compensation: the most-scrutinized section
Part VII requires disclosure of compensation for:
- Officers, directors, and trustees
- Key employees (defined specifically in IRS instructions)
- The five highest-paid employees who are not officers, directors, trustees, or key employees
Compensation includes base salary, bonuses, deferred compensation, and the value of benefits. The figures must match W-2 and 1099 data. Discrepancies between Part VII totals and the underlying payroll records are among the most common IRS exam triggers.
Compensation above $150,000 for any individual listed in Part VII requires completing Schedule J. Schedule J asks about the approval process, comparability analysis, and benefit components. The absence of a documented comparability analysis for executive compensation is a governance finding that sophisticated funders and state regulators notice.
Restricted net assets: the reconciliation trap
Form 990 requires reporting of net assets in three categories: unrestricted, temporarily restricted (now “net assets with donor restrictions” under ASC 958-205), and permanently restricted. These figures must reconcile with the audited financial statements. Discrepancies — even ones caused by different presentation conventions between the 990 and the audit — generate questions from state regulators, grant funders, and board members.
Organizations with multiple grants and multiple restrictions benefit from tracking restricted fund balances in a system that can generate the reconciliation automatically at year-end rather than constructing it manually from grant files.
Automatic revocation: the three-year rule
IRC Section 6033(j) provides that an organization that fails to file required annual returns for three consecutive years automatically loses its tax-exempt status. Automatic revocation is a legal event — the IRS posts the organization on a public list of auto-revoked entities. Reinstatement requires a new application (or a streamlined application for small organizations) and does not retroactively restore exempt status for the revocation period.
Many organizations discover auto-revocation only when a grant funder checks the IRS database and finds the organization on the revocation list.
State implications of the Form 990 extension
Many states accept the federal Form 990 extension as a basis for extending state charitable registration renewal. California’s RRF-1 follows the federal extension automatically when documented. New Jersey’s CRI-300R does not automatically extend; Ohio’s CFR-1 does not provide automatic extensions. Organizations that file Form 8868 and rely on it to extend state filings should verify each state’s policy before treating the federal extension as universal.
How GrantPipe helps
GrantPipe tracks the Form 990 due date, extended due date, and Schedule D restricted fund balances alongside state charitable registration renewals and federal grant reporting requirements in one operating record. The restricted fund module generates the net asset reconciliation that Part XII of Form 990 requires, reducing the manual reconciliation work at year-end. Start with a free trial to see how the compliance calendar, restricted fund tracking, and grant reporting workflow fit into one system.
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- Form 990
- The IRS annual information return required of most tax-exempt organizations. Discloses revenue, expenses, program activities, officer compensation, and governance practices. It is a public document.
DEFINITION
- Form 990-EZ
- A shorter version of Form 990, available to organizations with gross receipts under $200,000 AND total assets under $500,000. Not available to private foundations.
DEFINITION
- Form 990-N
- An electronic postcard filed by very small organizations with gross receipts normally $50,000 or less. Requires only basic identifying information. Organizations that can file 990-N but choose to file 990-EZ or 990 may do so.
DEFINITION
- Schedule B
- Schedule of Contributors. Lists donors who contributed $5,000 or more during the year. The IRS copy includes names and addresses; the public copy may redact donor identifying information for most 501(c)(3) public charities.
DEFINITION
- Form 8868
- Application for Automatic Extension of Time to File an Exempt Organization Return. Filing Form 8868 by the original due date grants an automatic 6-month extension. No reason is required.
DEFINITION
- IRC Section 6033(j)
- The Internal Revenue Code provision that automatically revokes tax-exempt status for organizations that fail to file required annual returns (990, 990-EZ, or 990-N) for three consecutive years.
DEFINITION
Q&A
What happens if a nonprofit fails to file Form 990 on time?
A penalty of $20 per day ($105 per day for larger organizations) applies for each day the return is late after the due date, up to the lesser of $10,500 (or $52,500 for larger organizations) or 5% of gross receipts. For organizations with gross receipts exceeding $1,074,900, the penalty is $105 per day up to $54,500. Separate penalties apply for failure to include required information. Three consecutive years of failure results in automatic revocation of tax-exempt status.
Q&A
Is Form 990 a public document?
Yes. Form 990 is a public document. The IRS makes 990s available through its Tax Exempt Organization Search tool. Third-party platforms like ProPublica Nonprofit Explorer and GuideStar also host 990 data. Schedule B donor identifying information is redacted on the public copy for most 501(c)(3) public charities, but all other schedules and the main form are publicly available.
Q&A
Can a 501(c)(3) that files 990-N also accept restricted grants?
There is no legal prohibition on a 990-N filer accepting restricted grants. However, grant funders increasingly require the full Form 990 as part of the application package. A 990-N filer that receives a grant large enough to push gross receipts above $50,000 will need to upgrade to 990-EZ or full 990 in that year.
Frequently asked