IRS Form 990 FAQs: A Practical Compliance Checklist
Form 990 is more than a tax filing. It is a public document that reflects your nonprofit’s governance, transparency, and credibility with funders, donors, and regulators.
This checklist answers the most common Form 990 questions asked by small and mid-sized nonprofits — in plain English.
1. When Is Form 990 Due?
☐ Due Date:
Form 990 must be filed by the 15th day of the 5th month after the end of your fiscal year.
Examples:
Fiscal year ends December 31 → Due May 15
Fiscal year ends June 30 → Due November 15
☐ Extension:
You may request an automatic 6-month extension by filing Form 8868 before the original due date.
2. Which Form 990 Do You File?
☐ Form 990-N (e-Postcard)
• Gross receipts normally $50,000 or less
☐ Form 990-EZ
• Gross receipts under $200,000
• Total assets under $500,000
☐ Form 990 (Full)
• Gross receipts $200,000 or more or
• Total assets $500,000 or more
Filing the wrong form is a common mistake. When in doubt, confirm with your tax preparer or the IRS instructions.
3. Does a CPA Have to Prepare or File Form 990?
No. A CPA is not legally required.
☐ Small nonprofits often prepare and file Form 990-N or 990-EZ internally
☐ Many organizations use:
A CPA
A nonprofit tax preparer
Accounting software (for very small orgs)
However:
Boards are still responsible for oversight, even if a CPA prepares the return.
4. What Board Members Are Actually Responsible For
Boards are not responsible for preparing Form 990 — but they are responsible for governance and review.
Before filing, boards should:
☐ Know which Form 990 is being filed
☐ Review the completed return (or a summary)
☐ Confirm accuracy of mission, programs, and board information
☐ Ensure conflicts of interest are disclosed
☐ Document board review or approval
Best practice: Review Form 990 before submission, not after.
5. Key Sections Boards Should Review
☐ Part I – Summary
(First thing the public sees)
☐ Part III – Program Service Accomplishments
(Does this match actual activities?)
☐ Part VI – Governance, Management & Disclosure
(Board structure, policies, independence)
6. Common Form 990 Mistakes
☐ Filing late or not filing at all
☐ Inconsistent mission or program descriptions
☐ Answering “yes” to policies you don’t actually have
☐ Incorrect or outdated board listings
☐ No documentation of board review
Remember: Form 990 is public.
7. What Is Filed vs. Kept Internal
Filed with the IRS:
☐ Form 990 / 990-EZ / 990-N
☐ Required schedules
Not filed (but kept internally):
☐ Board policies
☐ Board meeting minutes
☐ Written consents
☐ Internal evaluations
8. Annual Form 990 Readiness Checklist
☐ Filing responsibility assigned
☐ Correct form selected
☐ Board reviews return before filing
☐ Conflict of interest policy current
☐ Board/officer list accurate
☐ Filing approval documented
9. Governance & Compliance Tools
Strong Form 990 compliance depends on clear governance systems.
This checklist is adapted from The Ultimate Guide to Nonprofit Management & Governance, which includes board role descriptions, conflict of interest policies, resolutions, and compliance tools aligned with Form 990 disclosures.
Learn more at legalease.guide
This resource is for educational purposes only and does not constitute legal or tax advice.
