Coming Soon: Mandatory Electronic Filing for IRS Form 990s

The recently signed Taxpayer First Act will require virtually all nonprofits to file their IRS Form 990 annual information return in electronic format, starting in 2021 for most organizations. Currently, only small organizations that file Form 990-N and certain other larger organizations (including some private foundations, trusts, and organizations with over $10 million in assets) are required to e-file their returns. The new requirement will apply to all 990-series filings, including Form 990-EZ and the full Form 990.

The e-filing requirement will be effective for tax years that begin on or after July 2, 2019, meaning nonprofits which started their fiscal year on or before July 1, 2019 will not be affected with respect to their 2019-2020 filings (due 2020). Specifically, the many nonprofits that started their tax year on July 1, 2019 will not need to submit their first mandatory e-filing until 2021 (covering the July 1, 2020–June 30, 2021 tax period). Additionally, organizations that start their tax year between July 2 and August 31, 2019 can obtain an automatic extension using Form 8868 to extend their filing deadline to 2021.  Finally, the IRS may choose, at a future date, to delay implementation of mandatory e-filing for nonprofits that currently file Form 990-EZ to 2022.  

Mandatory e-filing will make it easier and faster for the IRS to make 990s publicly available on its website. By requiring all returns to be filed in an electronically readable format, the new requirements will also make it easier to search and conduct research using 990 data.