- April 27, 2026
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Julie A. Davis, CPA
On April 23, 2026, the U.S. Department of the Treasury announced that the IRS plans to revise Form 990 to increase transparency and strengthen oversight of tax-exempt organizations.
While no changes are in effect yet, the direction is clear: there will be more focus on how nonprofits receive, control, and use funds—particularly government funding and tax-deductible contributions.
For organizations receiving public dollars or operating under fiscal sponsorship arrangements, this is something to follow.
What changes are being proposed?
The IRS intends to enhance reporting requirements in several key areas, including:
- Greater transparency around government grants and contracts
- Clearer disclosure of fiscal sponsorship arrangements
- More visibility into who controls funds and how those funds are used
- Improved ability to detect fraud, abuse, or misuse of charitable resources
These updates are aimed at giving both regulators and the public a clearer picture of how nonprofit funds flow and are managed.
Why does this matter for nonprofit organizations?
Organizations that receive public funds or tax-deductible donations should be prepared to clearly demonstrate accountability in their financial reporting. That includes not just where funds come from, but who controls them and how they are ultimately used.
As reporting requirements evolve, transparency will continue to be a key expectation.
This also aligns with broader federal efforts to strengthen oversight of organizations receiving government funding, including recent updates to the 2025 Compliance Supplement.
When will these changes take effect?
There are no immediate changes to Form 990 at this time.
The Treasury and the IRS have announced that proposed regulations will be issued, followed by a public comment period. Factors such as reporting burden and administrative feasibility will be considered before any updates are finalized.
What should organizations be doing now?
At this stage, there’s no action required—but it’s a good time to be proactive.
Organizations may want to:
- Review how grants, contracts, and sponsorship arrangements are currently reported
- Ensure there is clear documentation around control and use of funds
- Stay informed as additional guidance is released
How RGCO is supporting nonprofit organizations
Rivero, Gordimer & Company (RGCO) will continue to actively monitor developments related to Form 990 and other matters affecting tax-exempt organizations.
Our team works closely with nonprofits to support accurate financial reporting, strong internal controls, and clear documentation—areas that will continue to be important as transparency expectations increase.
As more details become available, we will provide additional guidance. In the meantime, if you have questions about how these proposed changes could impact your organization, a member of our nonprofit team is available to talk through your specific situation.
Frequently Asked Questions
What is Form 990?
Form 990 is the annual information return that most tax-exempt organizations must file with the IRS. It provides visibility into a nonprofit’s finances, governance, and activities, and is often reviewed by regulators, donors, and the public.
Are the Form 990 changes already in effect?
No. The Treasury and IRS have announced planned updates, but no changes have been implemented yet. Proposed regulations will be released first, followed by a public comment period before anything becomes final.
What types of nonprofits will be most affected by the Form 990 changes?
Organizations that receive government grants or contracts, as well as those involved in fiscal sponsorship arrangements, are likely to see the most impact. These areas are a key focus of the proposed transparency updates.
What is a fiscal sponsorship arrangement in a nonprofit context?
Fiscal sponsorship is a structure where a tax-exempt organization supports a charitable project that does not have its own tax-exempt status. The proposed changes aim to provide clearer reporting around who controls the funds and how they are used.
Why is the IRS focusing more on transparency for nonprofits now?
Recent congressional oversight has raised concerns that some fiscal sponsorship arrangements may make it harder to see who is operating a project, who controls the funds, and how the money is being used. The Treasury also noted that government grants and contracts can involve substantial public funds, making clearer reporting important for understanding where funds come from and how they are spent. The proposed changes are intended to reduce the risk of fraud or misuse and strengthen accountability.
How can nonprofits prepare for potential Form 990 changes?
Organizations can start by reviewing how they currently report grants, contracts, and sponsorship arrangements, and ensuring they have clear documentation around control and use of funds. Staying informed as guidance evolves will also be important.
Will these changes increase reporting requirements for nonprofits?
It’s possible. While details are not finalized, the proposed updates are expected to expand disclosure in certain areas. The IRS has indicated it will consider reporting burden and administrative feasibility before finalizing any changes.
Who should nonprofits talk to if they have questions about Form 990 reporting?
Nonprofits should work with advisors who are familiar with tax-exempt organization reporting and compliance. Having guidance in place can help organizations stay ahead of changes and avoid issues as requirements evolve. RGCO’s nonprofit team works closely with organizations on Form 990 reporting, financial transparency, and evolving regulatory requirements. If you have questions about how these proposed changes may affect your organization, our nonprofit team is available to talk through your specific situation.
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