When the first return is due
The annual return or notice is generally due on the 15th day of the fifth month after the tax year ends. A calendar-year organization whose year ends December 31 generally has a May 15 deadline. If the due date falls on a weekend or legal holiday, the deadline moves to the next business day.
The deadline is based on the organization's tax year—not the date it submitted Form 1023 or Form 1023-EZ and not the date the IRS expects to decide the application.
Which Form 990-series filing applies?
| General financial threshold | Usual filing option |
|---|---|
| Gross receipts normally $50,000 or less | Form 990-N (e-Postcard), if otherwise eligible |
| 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 |
These are general IRS thresholds, not a complete eligibility test. Private foundations and certain other organizations use different forms or rules. Confirm the current instructions for the organization's classification and activities.
How to file while the application is pending
- Confirm the tax year and deadline. Use the accounting period reported to the IRS and calculate the fifth-month deadline.
- Select the correct filing. Review gross receipts, total assets, organization type, and the current IRS instructions.
- Show that the application is pending. On Form 990 or Form 990-EZ, check the application-pending box on page 1. Follow the current IRS procedure for any other applicable Form 990-series filing.
- File even without a determination letter. Keep the electronic acceptance or other filing confirmation with the permanent records.
- Track related obligations. If the organization has more than $1,000 in gross unrelated business income, the IRS says Form 990-T may also be required.
Why missing the filing matters
An organization that misses its required Form 990-series filing for three consecutive years is automatically revoked. Filing while an application is pending does not approve the application, but failing to file can create a separate compliance problem.
Forms 990 and 990-EZ filed while an application is pending are generally subject to public disclosure. Prepare the return with the same care you would use after approval.
A practical first-year checklist
- Record the organization's tax-year end in the board minutes and compliance calendar.
- Save the EIN confirmation, filed Articles, exemption application, and Pay.gov receipt.
- Start bookkeeping when the organization begins receiving or spending money.
- Choose the appropriate 990-series filing based on current-year facts.
- Preserve the filing acceptance and a complete copy of the return.
- Track state annual reports, charitable-solicitation filings, and other deadlines separately.
Frequently asked questions
Do I file Form 990 before my 501(c)(3) application is approved?
Yes. If an annual Form 990-series return or notice is due while the application is pending, the IRS says the organization still must file and indicate that its exemption application is pending.
When is a nonprofit's Form 990 due?
A Form 990-series return or notice is generally due on the 15th day of the fifth month after the tax year ends. For a calendar-year organization, that is generally May 15 of the following year.
Which Form 990 does a small nonprofit file?
Organizations with gross receipts normally at or below $50,000 are generally eligible for Form 990-N. Organizations below both the $200,000 gross-receipts and $500,000 total-assets thresholds may generally file Form 990-EZ or Form 990. Special organization types and exceptions can require a different form.
What happens after three missed annual filings?
The IRS automatically revokes the tax-exempt status of an organization that fails to file a required Form 990-series return or notice for three consecutive years.
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