Ask twelve questions, give each one an owner and a date, and keep proof of each answer. The questions cover the right return and year, the program story, the numbers, the schedules, the people and their pay, relationships, policies, the board-review answer on line 11, one consistent story, the signature and the public copy. The law says the board does not have to review Form 990. Good practice is a short review your board can repeat every year, and this is that review.
A Form 990 board review checklist turns a long return into twelve questions a director can ask without being a tax preparer. Use it after the draft is ready and before an officer signs. It is written for the full Form 990 and based on the 2025 form and its instructions. If you are asking whether the board must approve the return at all, start with does the board have to approve the Form 990. This article is the review itself.
What are the twelve questions to ask before Form 990 is filed?
Good practice is to give every question to the person who knows the answer. The owners below are typical. Change them to fit your staff and bylaws. The question numbers match the printable checklist in the free download.
| Ask | Who usually answers | Proof that closes it |
|---|---|---|
| 1. Right return, right year. Are the legal name, EIN, tax year and return type correct, and is the due date, or a timely Form 8868 extension, on the calendar? | Finance lead | A calendar date for the due date, or the filed extension |
| 2. The program story. Do the program descriptions in Part III match what we really did this year, including programs started, changed or ended? | Chief executive | The chief executive’s written okay of the program text |
| 3. The numbers. Do revenue, expenses, assets and liabilities in Parts VIII to XI match our financial statements, or is each difference explained and written down? | Finance lead and treasurer | A short note tying the return to the year-end financial statements |
| 4. Schedules. Part IV decides which schedules apply, and every “Yes” there needs its schedule. Is every schedule that applies attached, and does each agree with the main form? Schedule O is required of every filer | CPA or preparer | The preparer’s list of schedules and why each applies |
| 5. People listed. Part VII lists current officers and directors whether or not they were paid. Is everyone who served during the year listed, including part-year ones, along with key employees and the highest paid staff? | Board secretary and HR | A year-end roster matched line by line to the return |
| 6. Pay. Does the pay reported for the calendar year match payroll records, and does the pay process the return describes match what the board really did? | Compensation committee chair and HR | The payroll report and the minutes showing how pay was set |
| 7. Relationships. Are the answers on independent voting members and on family or business ties among officers, directors and key employees true, based on this year’s signed disclosure forms? | Governance committee chair | This year’s signed disclosure forms |
| 8. Policies. Do the answers on conflict of interest, whistleblower and document retention describe policies the board adopted by year-end, not policies it plans to adopt? | Board chair and secretary | Minutes showing the adoption date of each policy |
| 9. Board review. Is our answer to line 11a true, and does Schedule O describe the review that really happened? | Board secretary | The date directors got the final return and the Schedule O text |
| 10. One story. Do the return and Schedule O agree with our minutes, website, audit or review report and grant reports? | Chief executive and CPA | A list of what was compared, with each difference settled |
| 11. Signature. Is the person signing an officer who is authorized to sign, and have they seen the exact final version? | Board chair | The signing date and the saved final version |
| 12. After filing. Has someone checked the public copy, saved the IRS acceptance and set next year’s calendar? | Finance lead and chief executive | The accepted acknowledgement, a checked public copy and a calendar entry |
Source: IRS Form 990 (2025) and Instructions for Form 990 (2025), Parts II, III, IV, VI, VII to XII. Owners and proof are BDI good practice, not IRS requirements.
Three of these questions come straight from the return’s own wording. For question 8, the IRS tells filers to answer “Yes” on a policy only if the governing body, or a committee it delegated, adopted the policy by the end of the tax year. For question 6, compensation is reported for the calendar year that ends with or within the tax year, so payroll has to tie to a calendar year, not the fiscal year. For question 5, the form says to list current officers and directors “regardless of amount of compensation.”
The form asks about policies the law does not require. Part VI, Section B says it requests information about policies not required by the Internal Revenue Code. A “No” on question 8 is not a violation. It is an honest answer, and it tells the board what to build.
How do you run the review so it actually gets done?
Good practice is five small steps with dates on the calendar. They are practice, not law:
- Put four dates on the calendar before the draft arrives: the draft, the director review, the signing and the filing or extension date.
- Send the complete final return, with all schedules, and the checklist to every voting director. Line 11a asks about the final return as filed, so send the corrected final before filing if the draft changed.
- Have each owner answer in writing. They answer the question and attach the proof. They do not rewrite the return in a meeting.
- Have the chair collect every open item and the secretary record the questions and answers in the minutes.
- Have the authorized officer sign only after the open items are closed, then save the filed return and the IRS acceptance.
What should you check on the public copy and after filing?
The return, with all its schedules and attachments, is open to public inspection. The IRS public disclosure overview says the return includes any schedules and attachments filed with the form. The first page of Form 990 is marked “Open to Public Inspection.” Question 12 asks someone to look at the copy that the public can see.
Contributor names and addresses get special treatment. The IRS page on contributors’ identities says an organization is generally not required to disclose publicly the names or addresses of contributors on its annual return, including Schedule B. That exclusion does not apply to private foundations or to political organizations described in section 527. The rest of Schedule B can still be public if it does not identify the contributor, so ask your preparer to prepare the public copy on purpose.
Keep Social Security numbers off the return. The instructions for Schedule O say not to include any Social Security number on that schedule, because the schedule is made available for public inspection.
Save the IRS acceptance. A 2025 Form 990 must be e-filed. The IRS says an e-filed return is not considered filed until the IRS accepts it, and a rejected return that fails to meet processing criteria is considered not filed (Publication 4163, written for e-file providers). The IRS sends its acceptance notice to the transmitter of the return, usually your software or filing provider, so ask for it and save it with the filed return.
Which questions should go to a specialist?
Call a specialist when a question turns up one of these. The checklist finds the question. It does not answer it:
- Pay, loans or deals involving a director, an officer, their family or their companies
- Work or grants outside the United States
- Political or lobbying activity
- A large gift or asset sale no one can explain
- A mistake you think is already in a filed return
Ask a CPA or a nonprofit attorney who works with exempt organizations. For a signer who may not be an officer, see our answer on who signs Form 990.
What does a completed checklist look like?
Here is a fictional example. River Arts Collaborative is the made-up calendar-year public charity from our article on board approval. Its CPA sends a draft five days before the deadline, and the treasurer reads it with the checklist. Three questions raise a flag. Each flag goes to its owner, with a date.
| Question | What the treasurer flagged | Owner and next step |
|---|---|---|
| 2. The program story | Part III still describes an after-school program the board ended in August | The chief executive sends the corrected program text to the preparer by the next morning |
| 9. Board review | Line 11a says “Yes,” but only the finance committee has seen the return | The secretary either sends the corrected final to every director before filing, which would make “Yes” true, or changes the answer to “No” and describes the committee review on Schedule O |
| 12. After filing | The proposed public PDF includes a contributor attachment no one has reviewed | The finance lead and the preparer check the disclosure rules before any copy goes out |
Fictional example for illustration. The facts and dates are made up.
The teaching point: nobody rewrote the return in the meeting. Each flag became a question with an owner and a date, and the answer will show up in the filed return. The free download below puts the twelve questions on one page, with a column for each owner and date.
Based on the 2025 Form 990 and its instructions, checked against the IRS pages on October 31, 2026. The IRS has posted a draft 2026 form, which keeps Part VI, lines 11a and 11b at the same numbers, but drafts can change and later lines may move. Filing rules depend on your organization’s classification, facts, tax year and state. Use the current IRS instructions and ask a qualified exempt-organization adviser about your situation.