The final 2025 Form 990 governs 2025 returns. The 2026 form is only a draft. Treasury’s plan to add reporting on government grants, contracts and fiscal sponsorship is only a plan. The IRS says its draft forms are not for filing and are subject to OMB approval, and that drafts of instructions usually have some additional changes before the final release. Good practice is to label every change final, draft, planned or notice, and to act only on the final ones.
News about Form 990 changes mixes three different things: rules that are final, drafts that may change and plans that have no rule behind them. A board that treats a plan as a rule wastes effort, and a board that ignores a final rule risks an error. This article labels each item and says what a board should do. It is a status report as of October 31, 2026 and is meant to be updated. It builds on the routing and deadline articles in this series.
What is changing on Form 990, and what is only planned?
Every item below has a label. Read the label first. The labels are ours, and they follow what each source says about itself.
| Item and status | What the source says | What a board should do |
|---|---|---|
| FINAL. 2025 Form 990 and instructions | The form and instructions for 2025 tax years. E-filing is required. See the instructions | Use them for a 2025 return. Do not use a draft |
| DRAFT. 2026 Form 990 and instructions | Early-release drafts marked “DRAFT—NOT FOR FILING.” The draft instructions are dated July 28, 2026. See the draft form and the draft instructions | Do not file or train on a draft. Ask your preparer which form year applies and when the final is expected |
| PLANNED. Treasury’s Form 990 transparency initiative, announced April 23, 2026 | Treasury says the IRS plans to revise Form 990 on government contracts, government grants and fiscal sponsorship, and expects proposed regulations and public comment first. See the announcement | Nothing to file yet. If you hold government grants or use fiscal sponsorship, tell your preparer to watch it |
| PLANNED. The 2026-2027 Priority Guidance Plan, September 29, 2026 | Lists guidance on exempt organization information reporting under section 6033, including fiscal sponsorship, and on donor advised funds. The plan says it gives no deadline for any project. See the plan | Add the items to your watch list. No action until guidance is published |
| NOTICE ISSUED. Section 4960 tax on excess executive pay, Notice 2026-36, June 5, 2026 | The covered-employee definition is broadened for tax years beginning after December 31, 2025. Proposed regulations are expected. See the IRS summary | If any employee could be paid over $1 million, or receive an excess parachute payment, call a specialist |
| FINAL. Audit threshold under 2 CFR 200.501 | The current rule says an entity that expends $1,000,000 or more of federal awards in a fiscal year must have a single or program-specific audit. See the rule | Ask your auditor which threshold applies to your fiscal year. Do not rely on older text |
| UNCHANGED. E-filing, the due date, Form 8868 and automatic revocation | The same rules we describe in our articles on late and missed returns | Keep the calendar. Nothing new to do |
Sources are linked in the table and in the Sources box. Statuses are as of October 31, 2026 and can change, so check the IRS pages before you rely on them.
What does the draft 2026 form change?
The draft instructions list one change. Their What’s New section says that, beginning tax year 2026, general funding contributions of more than $5,000 made to fund a qualified general contribution for a qualified class of account beneficiaries of Trump accounts are addressed on line 23 of Part IV and reported on line 3 of Part IX. The draft Part IV line asks whether the organization reported more than $5,000 of such contributions on Part IX, line 3, and says to complete Schedule I, Part II if the answer is “Yes.”
The new lines shift the numbers after them. Because a new line 23 and a new Part IX line 3 are inserted, later lines in Part IV and Part IX move down by one. The draft puts the Schedule J question on Part IV, line 24, where the 2025 form has line 23. Cite a line number only with its form year. Part VI, lines 11a and 11b, keep the same numbers in the draft. See Part VI explained.
A draft can still change. The IRS cover sheet on each draft says to not file draft forms, that forms and instructions are subject to OMB approval before they can be released and that drafts of instructions usually have some additional changes before the final release. Most organizations will answer “No” to the new line. Plan your 2026 calendar around the final form when the IRS posts it.
What did Treasury announce, and is it a rule yet?
No. It is an announcement of a plan. On April 23, 2026, Treasury announced that the IRS plans to revise Form 990 to improve transparency and give clearer reporting on certain activities of section 501(c)(3) organizations, including government contracts, government grants and fiscal sponsorship arrangements. The announcement says Treasury and the IRS expect to publish proposed regulations and provide an opportunity for public comment before any reporting changes are finalized, and that they will consider administrative feasibility, proportionality and reporting burden.
The September 29, 2026 plan keeps it on the list. The Priority Guidance Plan for October 1, 2026 through September 30, 2027 includes guidance under section 6033 on exempt organization information reporting, including fiscal sponsorship, and guidance under sections 4966 and 6033 on certain donor advised fund arrangements. The plan says it does not provide any deadline for completing its projects. It also lists guidance on the political campaign prohibition. The draft 2026 form’s What’s New section does not mention any of these, so they are not yet part of the form.
Which tax-law changes touch what boards oversee?
Section 4960 is the one to know if you pay high salaries. The IRS says the tax applies to an applicable tax-exempt organization that pays a covered employee remuneration over $1 million in a year or an excess parachute payment. Before the 2025 law, a covered employee was one of the five highest-compensated employees. The IRS says that for tax years beginning after December 31, 2025, any employee can be a covered employee, unless an exception applies. Notice 2026-36 lets organizations rely on limited-hours and nonexempt-funds exceptions until further guidance. Proposed regulations are expected. This is a tax rule, not a Form 990 line, so ask a nonprofit tax specialist whether it reaches you.
Check the audit threshold in Part XII. Part XII, line 3a asks whether the organization was required to have an audit under the federal grant rules. The current 2 CFR 200.501 uses $1,000,000. The final 2025 Form 990 instructions still describe the requirement as $750,000, and the draft 2026 instructions say $1,000,000 (previously $750,000). If you spend federal awards, ask your auditor which rule applies to your fiscal year.
What dates should you watch?
These dates follow the IRS rules and the weekend rule. For a calendar-year organization, a 2025 return on extension is due on November 15, 2026, which is a Sunday, so it moves to Monday, November 16, 2026. A 2026 return is due on May 15, 2027, a Saturday, so it moves to Monday, May 17, 2027, and the extended due date is Monday, November 15, 2027. The instructions say that a due date on a Saturday, Sunday or legal holiday moves to the next business day, and that Form 990-N cannot be extended. Check the IRS due-date page for your year-end.
How should a board keep up with changes?
Good practice is a short routine, not a news habit. These steps are practice, not law:
- Give one person the job of checking the IRS Form 990 page and the draft forms page on a set day each month, and give them a backup.
- Keep a one-page status sheet with three columns: final, draft and planned. Put the date on it.
- Ask the preparer at the start of each filing season which form year and which instructions apply, and write the answer in the minutes.
- Treat a draft or a plan as a watch item. Change a policy or a process only when a final rule requires it.
- Call a specialist about anything that touches executive pay, federal awards or fiscal sponsorship.
What does a status sheet look like?
Here is a fictional example. River Arts Collaborative is the made-up calendar-year public charity from our other Form 990 articles. Its treasurer brings a status sheet to the finance committee in January.
| Item | Label | What the committee decided |
|---|---|---|
| 2025 Form 990 | Final | The preparer uses it for the 2025 return, and the committee records that in the minutes |
| 2026 Form 990 | Draft | The committee waits for the final form. It asks the preparer to say when it is posted |
| Treasury transparency plan | Planned | River Arts holds a county grant, so the treasurer will check the IRS page each month and tell the preparer if a proposal appears |
| Section 4960 | Notice issued | No employee is near $1 million, so the committee records that no action is needed this year |
Fictional example for illustration. The facts are made up.
The teaching point: the sheet kept the board from acting on a plan and from missing a final rule. It also gave the committee a reason to meet in the same month every year. The free download below is built on the final 2025 form.
Status as of October 31, 2026, from the IRS, Treasury and eCFR pages named above. Draft forms, plans and notices can change or be withdrawn, so check the IRS Form 990 page and the sources before you rely on anything here. Filing rules depend on your organization’s classification, facts, tax year and state. This article is general education, not legal or tax advice. Ask a qualified exempt-organization adviser about your situation.