The U.S. Department of the Treasury announced this week that it is considering significant revisions to Form 990, the annual information return filed by most tax‑exempt organizations, as part of a broader initiative to strengthen transparency and oversight in the not-for-profit sector.
According to the Treasury, the IRS plans to propose updates to Form 990 reporting focused on greater clarity around government grants and contracts, fiscal sponsorship arrangements, and control over funds and activities. Treasury officials indicated these changes are intended to help the IRS and the public better understand how tax‑exempt organizations receive, manage, and use public and tax‑advantaged resources.
While no revisions have been finalized, Treasury and the IRS confirmed that proposed regulations will be issued and opened for public comment before any new reporting requirements take effect. As part of that process, the agencies stated they will consider administrative feasibility, proportionality, and reporting burden on organizations.
Potential Impacts
If adopted, these proposals could result in expanded disclosures within Form 990, particularly for organizations that receive government funding or participate in fiscal sponsorship structures. Treasury officials emphasized that the goal is increased accountability and transparency, noting that tax‑exempt status does not shield organizations from scrutiny.
Looking Back
Many not-for-profits may recall that the last major redesign of Form 990 occurred for the 2008 filing year, when the IRS substantially expanded the core form and added numerous schedules to capture more detailed information about governance, compensation, fundraising, and program activities. That revision marked a significant shift in how the IRS evaluates not-for-profit compliance and transparency, and it required organizations to make meaningful updates to their internal reporting processes.
What’s Next
Although the current announcement does not impose immediate filing changes, it signals that Form 990 modernization is now under active discussion. Not-for-profits — particularly those receiving government grants, holding government contracts, or operating under fiscal sponsorship arrangements — may wish to monitor developments closely and be prepared to participate in the public comment process once proposals are released.
Have questions about potential Form 990 changes? A CBIZ professional can help you plan with confidence. Connect with us today.
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