Form 990: A Change is Gonna Come

Back in April 2026, the U.S. Department of the Treasury announced that they were exploring revisions to the Form 990 for all filers for the first time since 2008. The areas of focus are disclosures related to government contracts/grants and fiscal sponsorship arrangements (if you are holding a fiscally sponsored project under your tax status).

The next step is for the Treasury & IRS to issue a “Notice of Proposed Rulemaking” outlining the changes. The public will then have an opportunity to comment before anything is finalized. This process typically takes time – usually about a year-plus. However, we know that we are not in typical times, so we’ll be watching for these proposed changes and related processes.

Given this current gift of time, we’d recommend that all our clients with either government contracts/grants and/or holding fiscally sponsored projects take a good look at your processes, controls & compliance to make any necessary changes. It’s also a good reminder to take the preparation of your 990 very seriously. Many groups do as it’s the public documentation of our work, but this is a flag that compliance expectations & scrutiny in the current environment are increasing. We have a primer on being a good fiscal sponsor and always feel free to reach out if you need support. We’ll keep you posted as these updates to the 990 evolve, so keep an eye on our blog & LinkedIn.