Almost every organization the IRS recognizes as tax-exempt under Section 501(a) has to file a Form 990 information return each year, and the question of who has to file Form 990 turns mostly on what kind of organization you are and how much money moves through it.1Internal Revenue Service. Annual Exempt Organization Return: Who Must File A handful of organizations are excused entirely, most notably churches. Everyone else picks one of four versions of the form based on size and structure. Miss three years in a row and the IRS automatically revokes your exempt status.2Internal Revenue Service. Automatic Revocation of Exemption
Which Exempt Organizations Are Covered
The filing rule reaches well beyond public charities. Civic leagues and social welfare groups under Section 501(c)(4), labor and agricultural organizations under 501(c)(5), business leagues and chambers of commerce under 501(c)(6), social clubs, fraternal societies, veterans’ organizations, and voluntary employee benefit associations all file annually.3Office of the Law Revision Counsel. 26 USC 6033 – Returns by Exempt Organizations Nonexempt charitable trusts described in Section 4947(a)(1) file as well, using Form 990, 990-EZ, or 990-PF depending on whether they are treated as private foundations.4Internal Revenue Service. 2025 Instructions for Form 990-PF Return of Private Foundation Section 527 political organizations have their own dollar triggers, covered further down.
The rule is straightforward: if you are tax-exempt, you report annually. Donors, journalists, and watchdog groups often treat the Form 990 as the primary window into how a nonprofit spends its money and compensates its leaders.5Internal Revenue Service. Instructions for Form 990 Return of Organization Exempt From Income Tax (2025)
Which Version You File
The version of the return depends on gross receipts and total assets at year-end. There are three tiers for most exempt organizations.
Form 990 (the full return) is required when gross receipts are $200,000 or more, or total assets are $500,000 or more. It asks for detailed disclosures about executive compensation, program accomplishments, governance practices, and complete balance sheets.
Form 990-EZ (the short form) is available when gross receipts are under $200,000 and total assets are below $500,000. It captures the essential financial data with less administrative burden. An organization that qualifies for the 990-EZ can always file the full Form 990 instead.
Form 990-N (the e-Postcard) is for organizations that normally receive $50,000 or less in gross receipts.6Internal Revenue Service. Filing Requirements for Churches and Religious Organizations It takes a few minutes and asks only for basic identifying information about the organization and its officers.
The word “normally” in the $50,000 threshold does real work. The IRS looks at an average over the organization’s existence or the last three years, not just the current year. A one-time spike in donations doesn’t necessarily push you out of e-Postcard eligibility, but sustained growth will.
All of these returns must now be filed electronically. Form 990 and Form 990-PF went electronic-only for tax years ending July 31, 2020, and later; Form 990-EZ joined the mandate for tax years ending July 31, 2021, and later.7Internal Revenue Service. E-file for Charities and Nonprofits Form 990-N was always electronic. Paper is no longer accepted.
Private Foundations Always File 990-PF
Private foundations play by a different rule. Every private foundation files Form 990-PF every year, regardless of financial activity or size. There are no gross receipts thresholds and no short-form alternative.4Internal Revenue Service. 2025 Instructions for Form 990-PF Return of Private Foundation A foundation that made no grants and earned no income during the year still files.
The 990-PF tracks the 1.39% excise tax on net investment income that domestic exempt private foundations owe under Section 4940(a) and calculates whether the foundation met its mandatory distribution requirements for the year. Foundations that fall short face a 30% tax on the undistributed amount. Foundations that engage in self-dealing, hold excess business holdings, make risky investments, or spend on non-charitable lobbying may also need to file Form 4720 to report excise taxes on those activities.8Internal Revenue Service. Form 4720
Section 527 Political Organizations
Tax-exempt political organizations under Section 527 have their own filing triggers. A Section 527 organization with annual gross receipts of $25,000 or more must file Form 990. For qualified state or local political organizations, the threshold is $100,000.9Internal Revenue Service. Political Organization Annual Reporting Requirements: Political Organizations Required to File Form 990 Political organizations that meet the asset and gross receipts limits for the 990-EZ may file that version instead. Political organizations cannot use the Form 990-N e-Postcard.
Who Doesn’t Have to File
Several categories of organizations are carved out of the annual filing requirement entirely.
Churches and religious organizations. Churches, interchurch organizations of local units, conventions or associations of churches, and integrated auxiliaries of a church do not file any Form 990 variant, regardless of size.1Internal Revenue Service. Annual Exempt Organization Return: Who Must File Unlike other exempt organizations, churches don’t have to apply for recognition of exempt status either. A church can still choose to file a Form 990 voluntarily if it wants the transparency.
Government-affiliated entities. State institutions whose income is excluded from gross income under Section 115, and governmental units or affiliates meeting the requirements of Revenue Procedure 95-48, are exempt from filing.
Subordinates covered by a group return. A subordinate organization included in a group exemption letter can be reported through a group return filed by its central (parent) organization rather than filing on its own. Each subordinate has to authorize this in writing every year.10Internal Revenue Service. 2025 Instructions for Form 990 Return of Organization Exempt From Income Tax
Certain political organizations. State or local political committees, political committees of state or local candidates, caucuses of state or local officials, and organizations required to report to the Federal Election Commission as political committees are exempt from the Form 990 filing requirement.11Internal Revenue Service. Annual Information Returns – Section 527 Political Organizations
When It’s Due
Form 990 is due by the 15th day of the 5th month after the close of your organization’s tax year. For a calendar-year filer, that means May 15.12Internal Revenue Service. Instructions for Form 990 Return of Organization Exempt From Income Tax (2025) – Section: When, Where, and How To File If the deadline lands on a weekend or federal holiday, it moves to the next business day.
Need more time? File Form 8868 for an automatic six-month extension.13Internal Revenue Service. Form 8868 Application for Extension of Time To File an Exempt Organization Return The extension is automatic, so you don’t have to explain why. An extension of time to file, though, is not an extension of time to pay any taxes owed.
What Happens If You Don’t File
The IRS does not treat a late Form 990 as minor paperwork. For organizations with gross receipts below $1,208,500, the penalty is $20 per day, up to the lesser of $12,000 or 5% of gross receipts for the year. Organizations above that receipts figure face $120 per day, capped at $60,000.14Internal Revenue Service. Exempt Organizations Annual Reporting Requirements – Filing Procedures: Late Filing of Annual Returns The same penalties apply when a return is filed but incomplete or incorrect. Individual managers can also be personally penalized $10 per day, up to $5,000, if the failure is attributable to them and they lack reasonable cause.15Office of the Law Revision Counsel. 26 USC 6652 – Failure to File Certain Information Returns
The bigger risk is losing exempt status altogether. An organization that fails to file its required annual return or notice for three consecutive years automatically loses its federal tax-exempt status. This isn’t discretionary; it happens by operation of law. Once revoked, the organization owes federal income tax on its earnings, has to file Form 1120 or Form 1041, and comes off Publication 78, meaning donor contributions are no longer deductible.2Internal Revenue Service. Automatic Revocation of Exemption Reinstatement is possible through a new Form 1023 or 1023-EZ application, but the process is easier and cheaper the sooner you act, and streamlined retroactive reinstatement is only available within 15 months of the revocation notice.16Internal Revenue Service. Automatic Revocation – How to Have Your Tax-Exempt Status Reinstated