Form 990 preparation checklist: what to collect from a nonprofit

The size of the group sets the form. The IRS chart below is the first thing to check, using the latest financial statements (IRS, Which Form 990 to file). A private foundation always files Form 990-PF, whatever its size (IRS, Which Form 990 to file).

For this chart, gross receipts are the total amounts the group took in during the year, from all sources, before any costs (Form 990 instructions). Use that IRS definition, not net income, when you read the chart. A group with a large one-time grant can cross a line in a single year, so check the word normally in the instructions before you pick the short form.

Form 990 is due by the 15th day of the 5th month after the year ends, which is May 15 for a calendar-year group (Form 990 instructions). The 2025 return was due May 15, 2026; because May 15, 2027 is a Saturday, the 2026 return slides to Monday, May 17, 2027 (Form 990 instructions). Form 8868 buys 6 more months (Form 8868 instructions). The return is filed electronically (Form 990 instructions).

Missing years cost more than a penalty. A group that fails to file for 3 years in a row loses its exempt status on the due date of the third return (Form 990 instructions). It may then owe income tax returns until it is reinstated (Form 990 instructions). Before you start, check that the status is current and ask for the IRS determination letter.

Also ask for last year’s Form 990 and any IRS letters since. The prior return gives you the start-of-year balances and the answers to repeat or update.

The core of the return is the year’s financial statements, audited, reviewed or internal, and the trial balance behind them. Ask for bank and investment statements for each account at year end.

Part IX splits every expense three ways. Functional expenses are costs sorted by purpose: program services, management and general, and fundraising. Ask how the group allocates shared costs, such as rent or the director’s salary, and get the worksheet.

Part III describes what the group did. For each major program, collect a short description, the people served and the expenses and grants tied to it. Board reports or grant reports often hold these figures already.

Part VI asks governance questions that need documents, not memory. It asks, for example, whether the group had a written conflict of interest policy at year end (Form 990 instructions). Collect the bylaws, any changes to the articles, board minutes, and the written policies on conflicts, whistleblowers and document retention.

Part VII lists officers, directors, trustees, key employees and the highest paid staff, with hours and pay. Pull pay figures from the Forms W-2 and Forms 1099 the group issued, plus pay from related groups. It also lists the five highest paid independent contractors who received more than $100,000 (Form 990 instructions).

Big salaries carry a newer test. For tax years beginning after 2025, the excise tax on pay over $1,000,000 reaches any employee of the group, not only its five highest paid (26 U.S.C. 4960). So ask for every employee’s total pay, including pay from related groups, before you answer the Form 4720 question.

Payroll records tie to Part V. Ask for the Forms 941, W-2 and W-3, and the Forms 1099-NEC sent to contractors, so the counts on the return match the filings.

Part IV of Form 990 is a checklist of its own: each yes points to a schedule. Map each schedule to its record before you send the client request, so you only ask for what applies.

A donor list is the group’s record of each contributor’s name, address and total gifts for the year, and it feeds Schedule B. Parts of Schedule B can be open to public inspection, and for most groups donor names stay private (Form 990 instructions). Store the list with tighter access than the rest of the file.

Some groups owe a second return. If gross income from unrelated trades or businesses is $1,000 or more, the group also files Form 990-T and pays tax on it (Form 990 instructions). Ask for income and costs of activities outside the mission, such as ad sales or a shop.

The finished return is public. A group must make its Form 990, with schedules and attachments, available for inspection, along with its exemption application (Form 990 instructions). An amended return stays open to inspection for 3 years from filing or from the original due date, whichever is later (Form 990 instructions).

Last, get the signed e-file authorization from an officer, and check state charity filings. Your state may want a yearly report or renewal with a copy of Form 990. The engagement letter template can set the date the client must send all of this.

• IRS, Which Form 990 to file: Form 990-N for gross receipts normally $50,000 or less, Form 990-EZ under $200,000 receipts and $500,000 assets, Form 990 above, and Form 990-PF for private foundations.
• Form 990 instructions: Due date, e-filing, revocation after 3 years of not filing, Part VI policy questions, the $100,000 contractor list, Schedule B privacy, the $1,000 Form 990-T rule and public inspection.
• 26 U.S.C. 4960: For taxable years beginning after December 31, 2025, the excise tax on remuneration over $1,000,000 applies to any employee of an applicable tax-exempt organization (P.L. 119-21, section 70416).
• Form 8868 instructions: Form 8868 requests a 6-month extension of time to file an exempt organization return.
• IRS, About Schedule B (Form 990): Schedule B is the schedule of contributors for Forms 990, 990-EZ and 990-PF.