Form 8872 Instructions: Schedules A and B, Filing, and Penalties

Form 8872 is the periodic report that Section 527 political organizations use to publicly disclose the contributions they accept and the expenditures they make. The instructions for Form 8872 cover four things that matter to a filer: whether you have to file at all, which reporting schedule you are on, how to itemize contributions and expenditures on Schedules A and B, and how to file electronically without tripping the 21% penalty for late or incomplete reports.¹ Form 8872 is separate from the annual income tax return (Form 1120-POL) and any required annual information return (Form 990 or 990-EZ).²

Who Has to File

Every tax-exempt political organization described in Section 527 of the Internal Revenue Code must file Form 8872 unless a specific exception applies.³ The requirement is tied to Form 8871, the initial notice of Section 527 status. An organization that reasonably expects its annual gross receipts to always stay below $25,000 is not required to file Form 8871, and without that obligation there is no Form 8872 requirement either. Once annual gross receipts reach $25,000, the organization must file Form 8871 within 30 days and start filing Form 8872 going forward.⁴

A qualified state or local political organization (QSLPO) is exempt if it meets all four of these conditions:

Its exempt functions are aimed solely at influencing state or local elections or offices.
State law requires it to report information similar to what Form 8872 requires.
It actually files those reports with the state.
The state makes the reports publicly available, and the organization makes them open to public inspection the same way Form 8872 would be.⁵

If your organization does not fit the exceptions, you file Form 8872 for every reporting period in which you accept a contribution or make an expenditure, even for small amounts.

Picking a Reporting Schedule

For Form 8872 purposes, an election year is any even-numbered year. In even-numbered years, your two options are monthly or quarterly reporting. In odd-numbered years, the options are monthly or semi-annual reporting. You must stay on the same schedule for the entire calendar year; you cannot switch mid-year.⁶

Quarterly Reporting

Quarterly reports are due by the 15th day after the end of each calendar quarter. The exception is the year-end report covering Q4, which is due by January 31 of the following year rather than January 15.⁷ Organizations on the quarterly schedule in an election year must also file a pre-election report and a post-general election report.⁸

Monthly Reporting

Monthly reports are due by the 20th day after the end of the month they cover. In an election year, no monthly reports are due for October or November; the pre-election and post-general election reports take their place. There is also no monthly report for December, because the January 31 year-end report covers that month.⁶

Pre-Election and Post-Election Reports

The pre-election report is the deadline most likely to slip. It must be filed by the 12th day before the election if filing electronically, or by the 15th day before the election if mailing by certified or registered mail, and it must cover all reportable contributions and expenditures through the 20th day before the election.⁵ Any deadline falling on a weekend or legal holiday shifts to the next business day.

Itemizing Contributions on Schedule A

Schedule A requires you to list each contributor whose aggregate contributions during the calendar year reach at least $200 by the end of the current reporting period, so long as at least some part of that total was accepted during this period.⁵ The $200 threshold is cumulative. Ten separate $25 contributions from the same person total $250 and trigger itemization.

For each itemized contributor, report:

Full name and mailing address.
Employer name. For individuals, list the employer’s name rather than a supervisor. Use “Self-employed” if applicable, or “Not employed” for someone with no employer. Enter “N/A” for non-individual contributors such as another organization.
Occupation. Use the contributor’s principal job title. For unemployed individuals, use a descriptive label such as “Retired,” “Student,” or “Homemaker.” Enter “N/A” for non-individuals.
Amount of each contribution. If a contributor made more than one contribution during the reporting period, report each one separately.
Aggregate year-to-date total through the end of this reporting period.⁵

In-kind contributions of goods or services are reported at fair market value. Transfers of funds from another political organization also go on Schedule A and follow the same itemization rules.

Itemizing Expenditures on Schedule B

Schedule B mirrors Schedule A on the spending side. List each recipient to whom the organization made expenditures totaling at least $500 during the calendar year, measured at the end of the current reporting period, if any of those expenditures were made during this period.⁵

For each itemized recipient, report:

Full name and mailing address.
Employer name and occupation, following the same rules as Schedule A.
Amount of each expenditure, reported individually, with in-kind expenditures at fair market value.
Purpose. Be specific. “Printing services for mail campaign” or “Consulting fees for voter outreach” is far better than “Campaign services.”⁵

Expenditures below the $500 threshold do not need individual entries, but they must be included in the summary totals. Sloppy tracking of small expenditures is a common reason a summary fails to reconcile, and that is exactly the kind of error that attracts a penalty notice.

Identifying Information and the Summary

The top of Form 8872 collects the organization’s full legal name, mailing address, and Employer Identification Number. The EIN must match exactly what appears on Form 8871; a mismatch can delay processing or trigger rejection. You will also list the custodian of records and the contact person, who can be the same individual, along with the date the organization was formed and an email address for IRS correspondence.

Check the box that describes the filing: initial report, amended report, final report, or change of address. If the organization has moved since the last filing, check “Change of address” in addition to the report type.

The summary ties the schedules together. Enter total itemized contributions from Schedule A and total itemized expenditures from Schedule B, then the non-itemized totals for amounts below the $200 and $500 thresholds. Enter the cash balance at the start of the reporting period, add contributions, subtract expenditures, and compare the ending balance to your organization’s internal financial records. Reconcile any mismatch before filing. A gap between Form 8872 and your bank records gets worse with time, not better.

Filing Electronically

All Forms 8872 covering periods that began on or after January 1, 2020 must be filed electronically.⁹ Paper filing is no longer accepted for these periods. Before you can e-file, the organization has to complete a setup process:

File Form 8871 electronically as the initial notice of Section 527 status.
After submitting Form 8871, have an authorized official print, sign, date, and mail Form 8453-X (Political Organization Declaration for Electronic Filing) to the IRS at Ogden, UT 84201.¹⁰
Wait for credentials. On receipt of Form 8453-X, the IRS mails a username and password to the organization. Those credentials let you file Form 8872 electronically and amend or finalize Form 8871.¹⁰

A submission is not complete until the IRS system returns a confirmation number. Keep that number. It is your proof of timely filing if a penalty dispute comes up later.

Penalties and Requesting Relief

The IRS imposes a penalty when an organization required to file Form 8872 fails to file by the due date, files but omits required information, or reports incorrect information. The penalty is 21% of the total contributions and expenditures to which the failure relates.¹

The penalty applies to the amount involved in the failure, not to the organization’s entire budget. If you filed on time but left $50,000 in contributions off Schedule A, the penalty is calculated against that $50,000. Even so, 21% of an unreported amount adds up quickly for an organization moving six- or seven-figure sums during an election cycle.

If you receive a penalty notice, you can request relief by submitting a written statement explaining the circumstances that prevented timely or complete electronic filing. Lay out the specific facts and include the date of any attempted paper filing. The IRS evaluates requests based on reasonable cause, meaning whether the organization took reasonable steps to comply and was prevented by circumstances outside its control.¹

Filing a Final Report When Terminating

Winding down carries two obligations. File a final Form 8872 with the “Final report” box checked, covering all remaining contributions and expenditures through the termination date. Then, because termination is a material change, file a final Form 8871 within 30 days of termination.¹¹

Skipping the final Form 8871 has real consequences. Any income the organization receives after the material change, including contributions, becomes taxable if the amended notice was not filed.¹² Organizations that wind down after an election cycle sometimes miss this because the operational focus has moved on. Put the 30-day deadline on the calendar the moment the decision to terminate is made.

Recordkeeping

The IRS does not set a retention period unique to Form 8872. The general rule is to keep records that support any item on a return until the period of limitations for that return expires. In most situations, that is at least three years from the date you filed. If the organization underreported gross income by more than 25%, the period extends to six years. If no return was filed or a fraudulent return was filed, there is no expiration; keep those records indefinitely.¹³

In practice, political organizations should keep contributor records, bank statements, receipts, vendor contracts, and copies of every filed Form 8872 and 8871 for at least three years after the final filing. If a penalty dispute or an unreported amount surfaces, those records are the only thing standing between the organization and a 21% bill it cannot contest.

1
Internal Revenue Service. Form 8872 – Penalties
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Internal Revenue Service. FAQs About the Annual Form Filing Requirements for Section 527 Organizations
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Internal Revenue Service. About Form 8872, Political Organization Report of Contributions and Expenditures
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Internal Revenue Service. Instructions for Form 8871
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Internal Revenue Service. Instructions for Form 8872
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Internal Revenue Service. Form 8872 – When to File
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Internal Revenue Service. Form 8872 Due Dates – Quarterly Reports
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Internal Revenue Service. Instructions for Form 8872
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Internal Revenue Service. Recent Legislation Requires Tax-Exempt Organizations to E-File Forms
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Internal Revenue Service. Form 8871 – Electronic Filing Required
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Internal Revenue Service. Form 8871 – Final Report
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Internal Revenue Service. Audit Technique Guide – Political Organizations – IRC Section 527
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Internal Revenue Service. How Long Should I Keep Records?