Form 990 Schedule B: Who Files, What to Report, and Disclosure

Form 990 Schedule B, the Schedule of Contributors, must be attached to your annual return whenever a single contributor gave your organization $5,000 or more in money or property during the tax year. If no contributor hits that threshold, you still have to say so by checking a box on the main return. There is no option to leave the question blank.¹

The $5,000 figure is an aggregate. You add up everything a person or entity contributed across the full year, including cash, grants, securities, and other property, not just individual gifts.² Organizations that don’t meet the threshold certify that fact on Form 990 Part IV, line 2; Form 990-EZ line H; or Form 990-PF Part I, line 2.¹

Who Reports Donor Names

Meeting the filing threshold and having to publish donor identities are two different questions. Only two categories of exempt organizations report contributor names and addresses on Schedule B:

Section 501(c)(3) organizations, including nonexempt charitable trusts and nonexempt private foundations
Section 527 political organizations

Every other exempt organization, including 501(c)(4) social welfare groups, 501(c)(6) business leagues, and 501(c)(7) social clubs, files Schedule B when it hits the $5,000 threshold but enters “N/A” in the name and address column and reports only the contribution amounts. Congress codified this change in the Taxpayer First Act of 2019. The reporting exemption does not relieve any organization of the obligation to collect and keep donor information in its own books.¹

The Narrower Rule for Larger Public Charities

Public charities classified under sections 509(a)(1) and 170(b)(1)(A)(vi) that meet the 33-1/3% public support test report a smaller slice of donors. Instead of listing every contributor at $5,000 or more, they list only those whose contributions also exceed 2% of total contributions reported on Form 990, Part VIII, line 1h (or Form 990-EZ, line 1). Both conditions have to be met.³ A charity with $2 million in total contributions would list only contributors who gave $5,000 or more and more than $40,000. Charities relying on the 10% facts-and-circumstances test do not qualify for this narrower rule.

What You Fill Out

Schedule B has three parts. Which ones you complete depends on your classification and the kinds of contributions you received.

Part I: Contributors

For each contributor meeting the reporting threshold, enter the name and address (or “N/A” if your organization is exempt from name reporting), the aggregate amount contributed during the year, and the type of contribution: cash, noncash, or payroll deduction. Each contributor gets a sequential number that carries through to the other parts.²

Part II: Noncash Property

If a reportable contributor gave property rather than cash, complete Part II for each such gift. You report the contributor’s number from Part I, a description of the property, the fair market value or your best estimate, and the date received.²

Part III: Exclusively Religious, Charitable, or Similar Contributions

Part III applies only to organizations described in section 501(c)(7), (8), or (10), such as social clubs, fraternal beneficiary societies, and domestic fraternal societies. When these organizations receive contributions earmarked exclusively for religious, charitable, scientific, literary, or educational purposes, they complete Parts I through III for every person whose gifts for those purposes exceeded $1,000 during the year. The Part III heading also asks for the total of all such gifts of $1,000 or less. If the gift was transferred to another organization, Part III asks for the recipient’s name and address and an explanation of the relationship.¹

What the Public Sees

Schedule B goes to the IRS, but the public does not see all of it. Under 26 U.S.C. § 6104, exempt organization returns are generally open for public inspection, with one carve-out: the IRS may not disclose the name or address of any contributor to an organization other than a private foundation or a section 527 political organization.⁴ When a 501(c)(3) public charity makes its Form 990 available to the public, Schedule B names and addresses are redacted. Contribution amounts and descriptions of noncash gifts stay visible unless those details alone would reasonably identify a specific donor.

Private foundations and 527 political organizations get no such protection. Their Schedule B contributor information, names and addresses included, is part of the publicly inspectable return.⁴

State charitable registrars are a separate matter. Some historically required unredacted Schedule B copies as a condition of soliciting in the state. In Americans for Prosperity Foundation v. Bonta (2021), the Supreme Court struck down California’s blanket demand, holding that compelled donor disclosure burdens First Amendment associational rights and must be narrowly tailored.⁵ If you register in a state that once collected Schedule B, confirm its current rule before submitting anything.

Records You Still Have to Keep

Even organizations exempt from reporting donor names on Schedule B must maintain contributor names and addresses in their own records. The IRS can request that information during an examination.¹ For noncash contributions, document the description of the property, the date received, and how you determined fair market value at the time of the gift. Retention periods vary by state, but keeping donor records for at least the length of the IRS statute of limitations on the return, generally three years from the filing date, is a sensible baseline.

Penalties for Late or Incomplete Filing

Because Schedule B is part of the annual return package, a missing or incomplete Schedule B can trigger the same penalties as a missing Form 990 under 26 U.S.C. § 6652(c). The base amounts are $20 per day up to the lesser of $10,000 or 5% of gross receipts for most filers, and $100 per day up to $50,000 for organizations with gross receipts over $1 million. These figures are adjusted annually for inflation for returns required after 2014, so the current amounts run higher than the base numbers in the statute.⁶ If the IRS sets a specific date to correct the return and the organization misses it, responsible individuals can be personally penalized $10 per day up to $5,000.⁷

The bigger risk is not the fine. Under section 6033(j), an organization that fails to file its required annual return for three consecutive years automatically loses its tax-exempt status. Revocation is effective on the filing due date of the third missed return, and getting exemption back requires a new application.⁸ Organizations that miss a deadline for reasons beyond their control can request penalty relief for reasonable cause.⁹

How to Submit

Schedule B is never filed on its own. It is attached to Form 990, Form 990-EZ, or Form 990-PF. The Taxpayer First Act made electronic filing mandatory for Form 990 and Form 990-PF filers for tax years ending on or after July 31, 2020; paper filing is no longer an option for those returns. Form 990-EZ filers may still paper-file in some cases, though electronic filing is encouraged.¹⁰ When e-filed, Schedule B is included in the electronic return package, and the contributor name fields are protected from public disclosure according to the organization’s classification.

1
Internal Revenue Service. Instructions for Schedule B (Form 990)
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Internal Revenue Service. Schedule B (Form 990) – Schedule of Contributors
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Internal Revenue Service. Instructions for Schedule B (Form 990)
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Office of the Law Revision Counsel. 26 U.S. Code 6104 – Publicity of Information Required From Certain Exempt Organizations and Certain Trusts
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Supreme Court of the United States. Americans for Prosperity Foundation v. Bonta
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Office of the Law Revision Counsel. 26 USC 6652 – Failure to File Certain Information Returns, Registration Statements, Etc.
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Internal Revenue Service. Annual Exempt Organization Return – Penalties for Failure to File
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Internal Revenue Service. Automatic Revocation of Exemption
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Internal Revenue Service. Penalty Relief for Reasonable Cause
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Internal Revenue Service. E-File for Charities and Nonprofits