Which Form 990 Does My Nonprofit Need to File?

Most tax-exempt organizations must complete an annual Form 990-series filing, but the correct form depends on the organization’s gross receipts, total assets, and tax classification.

Filing the wrong form can create delays, produce inaccurate public information, or leave important reporting requirements unanswered. Here is how to determine which Form 990 your nonprofit will generally need to file.

Form 990-N: For Most Small Nonprofits

Form 990-N, commonly called the e-Postcard, is generally available to eligible organizations whose annual gross receipts are normally $50,000 or less.

The filing is short, but it is still an annual IRS requirement. The organization must provide basic information such as:

• Its legal name and Employer Identification Number
• Any names under which it operates
• Its mailing address and website
• The name and address of a principal officer
• Confirmation that its annual gross receipts are normally $50,000 or less
• Confirmation that the organization is still operating

An organization eligible for Form 990-N may voluntarily file Form 990-EZ or Form 990 instead, but doing so creates a more extensive public filing.

Form 990-EZ: For Small and Midsized Nonprofits

A nonprofit can generally file Form 990-EZ when both of the following apply:

• Gross receipts are less than $200,000
• Total assets at the end of the tax year are less than $500,000

Both requirements must be satisfied. For example, an organization with only $150,000 of gross receipts but $600,000 of total assets generally must file the full Form 990.

Form 990-EZ requires substantially more information than Form 990-N. It reports the organization’s revenue, expenses, assets, liabilities, programs, leadership, governance, and other activities. Depending on the organization, additional schedules may also be required.

Some organizations choose to file the full Form 990 even when they qualify for Form 990-EZ. This may be appropriate when a nonprofit wants to provide more complete public information or when a funder, lender, or other stakeholder expects the full return.

Form 990: For Larger or More Complex Nonprofits

A nonprofit generally must file the full Form 990 if either of the following applies:

• Gross receipts are $200,000 or more
• Total assets at the end of the tax year are $500,000 or more

The full Form 990 provides detailed information about the organization’s finances, programs, governance, compensation, fundraising, grants, related organizations, transactions, and public support.

The return is publicly available, so it is more than a tax-compliance document. Potential donors, grantmakers, board members, lenders, regulators, and rating organizations may use it to evaluate the nonprofit.

Organizations that meet certain conditions may also be required to file the full Form 990 regardless of their size. These can include certain supporting organizations, hospital organizations, donor-advised-fund sponsoring organizations, and other specialized entities.

Form 990-PF: For Private Foundations

Private foundations generally file Form 990-PF regardless of their revenue or asset level.

This includes many family foundations, grantmaking foundations, and private operating foundations. A private foundation with very little activity may still have a Form 990-PF filing requirement.

Form 990-PF contains specialized reporting for:

• Investments and investment income
• Grants and charitable distributions
• Trustee, director, and officer compensation
• Excise tax
• Minimum investment return
• Qualifying distributions
• Undistributed income
• Excess-distribution carryovers
• Transactions involving disqualified persons

A private foundation should not use Form 990-N or Form 990-EZ merely because it has limited revenue or assets.

Form 990-T: When a Nonprofit Has Unrelated Business Income

Form 990-T is not a substitute for the organization’s regular Form 990-series filing. It is an additional return that may be required when a nonprofit has $1,000 or more of gross income from an unrelated trade or business.

Whether an activity creates unrelated business taxable income depends on the facts. Income is not automatically exempt simply because a nonprofit earned it.

Examples requiring additional review can include certain advertising activities, regularly conducted business activities unrelated to the exempt purpose, and some debt-financed income.

Organizations That May Not Have to File

Certain organizations may be excepted from the annual Form 990-series filing requirement. Common examples include:

• Churches
• Certain church-affiliated organizations
• Certain governmental organizations
• Some organizations included in a group return
• Certain political organizations
• Organizations specifically excepted under IRS rules

Religious status alone does not automatically mean an organization qualifies for the church exception. The organization should confirm that it fits within a specific filing exception before deciding not to file.

When Is Form 990 Due?

A Form 990-series return is generally due on the 15th day of the fifth month after the end of the organization’s tax year.

For a nonprofit with a December 31 year-end, the normal due date is May 15. For a nonprofit with a June 30 year-end, the normal due date is November 15.

Many organizations can request an automatic six-month extension by timely filing Form 8868. Form 990-N cannot be extended.

What Happens If a Nonprofit Does Not File?

Late or missing returns can result in IRS penalties. More importantly, an organization that fails to file a required Form 990-series return or notice for three consecutive years generally loses its federal tax-exempt status automatically.

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Reinstating tax-exempt status can require a new exemption application, delinquent filings, a reasonable-cause request, and additional professional fees. Filing the correct return on time is far easier than correcting an automatic revocation later.

Quick Form 990 Filing Guide

Use this as a general starting point:

• Gross receipts normally $50,000 or less: Form 990-N may be available
• Gross receipts under $200,000 and total assets under $500,000: Form 990-EZ or Form 990
• Gross receipts of $200,000 or more, or total assets of $500,000 or more: Form 990
• Private foundation: Form 990-PF
• At least $1,000 of gross unrelated business income: Form 990-T may also be required

These thresholds do not override special filing rules or exceptions that apply to certain types of organizations.

Get Help With Your Nonprofit’s Form 990

Choosing the correct return is only the first step. The filing must also agree with your accounting records, properly report restricted contributions and functional expenses, include all required schedules, and clearly explain your organization’s programs.

The NonProfit CPA provides specialized Form 990 preparation and filing for nonprofit organizations nationwide. We prepare Forms 990-N, 990-EZ, 990, 990-PF, and 990-T and can also help identify issues in prior-year filings.

Book a free consultation to discuss your organization’s filing requirements.

The filing thresholds and requirements in this article are based on current IRS Form 990-series guidance. Special rules and exceptions may apply based on an organization’s classification and activities.