Form 990 is the annual information return that most federally tax-exempt nonprofit organizations must file with the IRS. It reports the organization’s finances, governance, compensation, and program activities, and it is a public document that anyone can read. Which version your nonprofit files depends on its size, and failing to file for three years in a row costs the organization its tax-exempt status automatically.
Which Version Your Nonprofit Files
The IRS offers four returns in the 990 series. The right one depends on gross receipts, total assets, and whether the organization is a private foundation.
- Form 990-N, the e-Postcard, is for small organizations whose annual gross receipts are normally $50,000 or less. It asks for basic identifying information and takes only minutes to file electronically.1Internal Revenue Service. Annual Electronic Filing Requirement for Small Exempt Organizations – Form 990-N (e-Postcard)
- Form 990-EZ is for organizations with gross receipts under $200,000 and total assets under $500,000 at year-end.2Internal Revenue Service. 2025 Instructions for Form 990-EZ
- Form 990, the full return, is required when gross receipts hit $200,000 or total assets hit $500,000. It runs over a dozen pages before schedules.2Internal Revenue Service. 2025 Instructions for Form 990-EZ
- Form 990-PF is required for all private foundations, regardless of size. A private foundation cannot use the standard 990 or 990-EZ even if its gross receipts are minimal.3Internal Revenue Service. 2025 Instructions for Form 990-PF
The “normally $50,000 or less” threshold for the e-Postcard is not a single-year snapshot. An organization that has existed for at least three years averages its gross receipts over the preceding three tax years. A first-year organization qualifies if it received or was pledged $75,000 or less. A second- or third-year organization qualifies if it averaged $60,000 or less.1Internal Revenue Service. Annual Electronic Filing Requirement for Small Exempt Organizations – Form 990-N (e-Postcard) Reassess each year, because a jump in revenue can push you into a higher filing tier.
Who Does Not Have to File
Churches, their integrated auxiliaries, and conventions or associations of churches are generally excluded from the annual filing requirement, and certain government organizations are also excused.4Internal Revenue Service. Exempt Organizations Annual Reporting Requirements – Overview – Annual Return Filing Exceptions These exemptions are narrower than people assume. A faith-based nonprofit that is not itself a church, or a religiously affiliated school that does not qualify as an integrated auxiliary, still has to file. Section 509(a)(3) supporting organizations generally must file Form 990 or 990-EZ even when church-affiliated, with limited exceptions for exclusively religious activities and very small supporting organizations. Political organizations described in Section 527 that must file an annual return use Form 990 or 990-EZ, not the e-Postcard.5Internal Revenue Service. Annual Electronic Notice (Form 990-N) for Small Organizations FAQs – Who Must File
What the Form Asks For
The full Form 990 covers four broad areas: mission and programs, finances, compensation, and governance.
On the mission side, filers describe their program service accomplishments with specific metrics. A food bank, for example, reports how many meals it distributed and how many people it served. Revenue is broken out by type: contributions, grants, program service revenue, investment income, and other sources. The balance sheet captures total assets, liabilities, and net assets at year-end.
Compensation reporting is where the IRS watches most closely for abuse. Organizations must list all current officers, directors, and trustees, whether or not they were paid. They must also report up to 20 key employees with reportable compensation over $150,000, and the five highest-compensated employees earning at least $100,000 who are not officers or key employees. The same disclosure applies to the five highest-compensated independent contractors paid more than $100,000.6Internal Revenue Service. Form 990 Part VII and Schedule J Reporting Executive Compensation Individuals Included
Part VI of the form asks pointed questions about internal controls: whether the organization has a conflict-of-interest policy, a whistleblower policy, a document-retention policy, and whether the board reviews the Form 990 before it is filed. These are not simple yes-or-no boxes. The IRS expects narrative explanations on Schedule O describing how the policies work in practice.
Schedule L requires disclosure of financial dealings with “interested persons,” including officers, directors, key employees, founders, substantial contributors, their family members, and entities they control. Reportable transactions include excess benefit transactions, loans in either direction, grants benefiting insiders, and business deals like leases and contracts.7Internal Revenue Service. Instructions for Schedule L (Form 990) Depending on activities, other schedules cover foreign operations, non-cash contributions, hospitals, and school nondiscrimination policies. Organizations with subordinate chapters under a group exemption ruling can sometimes file a group return through the parent, provided the subordinates agree to be included.8Internal Revenue Service. Exempt Organizations Annual Reporting Requirements – Overview – Returns by Members of Group Ruling
When It Is Due and How to File
The return is due on the 15th day of the 5th month after the end of the organization’s tax year.9Internal Revenue Service. Exempt Organization Annual Filing Requirements Overview For a calendar-year organization, that is May 15. Filing Form 8868 before the deadline gets an automatic six-month extension, pushing a calendar-year filer to November 15, and no explanation is required.10Internal Revenue Service. Extension of Time to File Exempt Organization Returns The e-Postcard cannot be extended.
All 990 series returns must be filed electronically. The Taxpayer First Act eliminated paper filing, and the IRS does not grant waivers, even for religious organizations.11Internal Revenue Service. Topic No. 803, Electronic Filing Waivers or Exemptions and Filing Extensions Use IRS-approved e-file software or an authorized transmitter.
Penalties for Filing Late
The IRS charges a daily penalty when a return is filed after the due date (including extensions) without reasonable cause. For organizations with gross receipts under $1,208,500, it is $20 per day, up to the lesser of $12,000 or 5 percent of gross receipts. For organizations with gross receipts over $1,208,500, it is $120 per day, up to $60,000.12Internal Revenue Service. Late Filing of Annual Returns The penalty is assessed against the organization, though responsible persons can face separate liability if the failure is willful.
What Happens If You Do Not File at All
If an organization fails to file a required return or notice for three consecutive years, its tax-exempt status is automatically revoked as of the filing date of the third missed return.13Office of the Law Revision Counsel. 26 U.S.C. 6033 – Returns by Exempt Organizations This is not discretionary. The IRS does not send a final warning. Revocation happens by operation of law.
During the gap between revocation and reinstatement, the organization is treated as a taxable entity, donations are not tax-deductible, and it may lose eligibility for grants that require current exempt status. Small organizations that simply forgot to file the e-Postcard get caught by this more often than you might expect.
To regain exemption, the organization must file a new application (Form 1023 or Form 1023-EZ for 501(c)(3) organizations) and pay a user fee of $600 for Form 1023 or $275 for Form 1023-EZ.14Internal Revenue Service. Form 1023 and 1023-EZ – Amount of User Fee Revenue Procedure 2014-11 sets out four reinstatement paths:15Internal Revenue Service. Automatic Revocation – How to Have Your Tax-Exempt Status Reinstated
- Streamlined retroactive reinstatement, for organizations that were eligible to file 990-EZ or 990-N during the three missed years and have not been auto-revoked before. The application must be submitted within 15 months of the revocation letter or the date they appeared on the IRS revocation list.
- Retroactive reinstatement within 15 months, for organizations that don’t qualify for the streamlined process. Requires a reasonable-cause statement covering at least one year of nonfiling, plus all delinquent returns.
- Retroactive reinstatement after 15 months, which requires a reasonable-cause statement covering all three consecutive years of nonfiling.
- Post-mark date reinstatement, the simplest option. Exempt status resumes from the date the application is mailed, with no retroactive effect. Donations received during the gap period may not be tax-deductible for donors.
Public Disclosure Obligations
Form 990 is public. Federal law requires a copy of the annual return to be available for inspection during regular business hours at the organization’s principal office and at any regional office with three or more employees. Anyone who requests a copy in person or in writing must receive one, with no charge beyond reasonable reproduction and mailing costs.16Office of the Law Revision Counsel. 26 U.S.C. 6104 – Publicity of Information Required From Certain Exempt Organizations and Certain Trusts The IRS also publishes electronically filed returns in machine-readable format.
Donor names and addresses on Schedule B are filed with the IRS but redacted from the public copy for most organizations. Private foundations and Section 527 political organizations are exceptions and must disclose contributor information. Political organizations must also report the name, address, occupation, and employer of anyone contributing $200 or more in a calendar year.17Internal Revenue Service. Public Disclosure and Availability of Exempt Organizations Returns and Applications – Contributors Identities Not Subject to Disclosure Failing to comply with public inspection rules carries a penalty of $20 per day, up to $10,000 per return. Willful noncompliance adds a flat $5,000 penalty.18Internal Revenue Service. Political Organization Filing Requirements – Penalties for Failing to Make Forms 990 Publicly Available
Two Filings People Often Miss
Tax-exempt organizations can still owe federal income tax on revenue from activities unrelated to their charitable mission. If your organization earns $1,000 or more in gross income from a regularly conducted unrelated trade or business, it must file Form 990-T and pay the tax owed.19Internal Revenue Service. Unrelated Business Income Tax A museum gift shop selling items tied to exhibits is generally fine. A nonprofit running a commercial parking garage open to the general public is likely earning unrelated business income. Form 990-T has its own deadline, which for most corporate-form organizations is the 15th day of the 5th month after the tax year ends, with a six-month extension available.20Internal Revenue Service. Return Due Dates for Exempt Organizations – Form 990-T (Corporations) Filing 990-T is separate from and in addition to Form 990.
Filing Form 990 with the IRS also does not satisfy state obligations. Most states require nonprofits to register before soliciting charitable contributions from residents, and those registrations typically renew annually with periodic financial reports.21Internal Revenue Service. Charitable Solicitation – State Requirements Some states accept a copy of the federal Form 990; others require separate forms. Fees vary widely and sometimes scale with revenue. Organizations soliciting online or by mail across state lines may need to register in each state where they ask for money.