Who Signs the Form 990? What the IRS Says About the Signer

Who the IRS says signs Form 990, what the signer declares under penalties of perjury, how the paid preparer fits in, how signing works when the return is e-filed and when to ask a nonprofit attorney. Based on the 2025 Form 990 and its instructions.

Silver-haired board chair guiding a discussion with colleagues around a meeting table.
The short answer

An officer who is authorized to sign as of the date the return is filed signs Form 990. The instructions say that means the president, vice president, treasurer, assistant treasurer, chief accounting officer or another corporate officer, such as a tax officer. The form asks the signer to declare, under penalties of perjury, that the return is true, correct and complete. A paid preparer signs in a separate box. Call a specialist if your usual signer is not an officer.

Who signs the Form 990 matters because the signature is a promise, not a formality. This article shows who the IRS lists, what the signer declares, how the paid preparer fits in, how signing works when the return is e-filed and when to ask a nonprofit attorney. It is based on the 2025 Form 990 and its instructions. For whether the board must approve the return, see does the board have to approve the Form 990. For the review that comes before signing, see the Form 990 board review checklist.

Who can sign Form 990?

The instructions say the return must be signed by the current president, vice president, treasurer, assistant treasurer, chief accounting officer or other corporate officer (such as a tax officer) who is authorized to sign as of the date the return is filed. That sentence is in the Part II instructions. “Tax officer” is an example, not a title you must have.

Two phrases do the work: “current” and “as of the date this return is filed.” The instructions look at who holds the office, and has the authority to sign, on the filing date. They do not look at who held it at year-end.

Who signs Form 990, by situation (based on the 2025 instructions)
If the filer isWho signs
A corporation or associationA current officer who is authorized to sign as of the filing date: president, vice president, treasurer, assistant treasurer, chief accounting officer or another corporate officer, such as a tax officer
A corporation or association with a receiver, trustee or assigneeThe receiver, trustee or assignee signs any return he or she files
A trustThe authorized trustee or trustees
Your usual signer is not on your officer listCall a specialist. Do not guess. See the next section

Source: IRS Instructions for Form 990 (2025), Part II, Signature Block.

Can an executive director who is not an officer sign?

Call a specialist. We do not decide that here, and a general article cannot. The answer depends on your bylaws and on how the instruction text applies to your facts.

Two things make it harder than it looks. The form uses two meanings of “officer.” The instructions say the definition of officer for Part II is different from the Glossary definition used to decide which officers to report elsewhere on the form and schedules. So the Glossary’s treatment of your top management official as an officer elsewhere on the form does not settle who may sign here. Your state or bylaws usually say who your officers are, and titles vary from one organization to the next.

Good practice is a short, written route to the answer. These four steps are practice, not law:

  • Read the Part II paragraph of the instructions and your own bylaws and board resolutions for the officer list and any signing authority.
  • Ask a nonprofit attorney one plain question: “May [name, title] sign our Form 990?” Attach the instruction text and the bylaws.
  • Hold the signature until the answer arrives. Do not let the return’s deadline pick the signer. If time is short, ask the preparer about an extension.
  • Record the answer in the minutes and keep it with the filed return.

What is the signer promising?

The form asks the signer to declare: “Under penalties of perjury, I declare that I have examined this return, including accompanying schedules and statements, and to the best of my knowledge and belief, it is true, correct, and complete.” That is the text above the signature line on the Form 990.

Read the three key words slowly. The signer says they examined the return, with its schedules and statements. They say it is true, correct and complete to the best of their knowledge and belief. The IRS does not say how closely a signer must read. That is why good practice matters more than a minimum.

The preparer’s promise is narrower. The form says the declaration of a preparer other than an officer is based on all information of which the preparer has any knowledge. A preparer may not know whether your board adopted a policy by year-end or whether your program descriptions match what you did. Hiring a preparer does not move the officer’s promise to someone else.

Good practice is for the signer to:

  • See the exact final version, not a draft that may have changed
  • Hear from each owner of the twelve review questions that the answers are true
  • Check that the answers on Part VI, lines 11a and 11b describe what really happened
  • Date the signature after the open items are closed, and save the signed copy

What does the paid preparer sign?

Anyone who is paid to prepare the return must sign it. The instructions say the paid preparer must sign in the space provided, enter the preparer information, including the preparer tax identification number (PTIN), and give a copy of the return to the organization. An employee of the filing organization is not a paid preparer, so a staff member who prepares the return does not use that box.

Watch the PTIN box. The instructions say to enter the PTIN, not a Social Security number. The IRS will not redact a Social Security number entered there, and Form 990 is a public document, so anything in that block is publicly disclosed.

The last line of Part II asks, “May the IRS discuss this return with the preparer shown above?” Checking “Yes” lets the IRS contact the individual preparer who signed. It does not extend to the preparer’s firm.

How does signing work when the return is e-filed?

A 2025 Form 990 must be e-filed, and an e-filed return needs a signature to be accepted. IRS Publication 4163, written for e-file providers, says an authorized representative must sign an electronic return and that a return without an appropriate signature is rejected.

For a Form 990 the signature usually runs through one of two forms. Form 8879-TE is the signature authorization used with a practitioner PIN, and it can be used only when a return originator files for you. Form 8453-TE is a declaration the authorized signer signs, which is then scanned and attached to the return. Which one applies depends on how your return is filed, so ask your preparer or filing software. Keep the signed form with the filed return.

What does it look like when the signer is unclear?

Here is a fictional example. River Arts Collaborative is the made-up calendar-year public charity from our other Form 990 articles. Its CPA sends the final return on a Thursday. The signature line carries the name of the executive director, who is not named as an officer in the bylaws.

The board chair does not guess. The secretary pulls the Part II paragraph of the instructions and the bylaws. The chair sends one question to the nonprofit attorney. The treasurer asks the CPA which e-file signature form the return needs. Nothing is signed until the attorney answers. Whoever signs reads the exact final version first, and the answer goes into the minutes.

The teaching point: the board did not leave the signer to habit or to the preparer. It asked a short question, got a written answer and kept it. The free download below includes the review checklist, with a signature question, and sample wording for the minutes.

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. Who may sign for your organization depends on your classification, bylaws, facts and state. This article is general education, not legal advice. Ask a qualified exempt-organization attorney about your situation.

FAQ

Common questions

Can the executive director sign Form 990?

That depends on your bylaws and on how the instructions apply to your facts, so ask a nonprofit attorney. The instructions say a current president, vice president, treasurer, assistant treasurer, chief accounting officer or other corporate officer who is authorized to sign as of the filing date must sign. Do not assume a job title settles it.

Can a paid preparer sign instead of an officer?

No. The preparer signs in the separate Paid Preparer Use Only box, and the preparer's declaration is based on the information the preparer has. An officer signs under penalties of perjury for the organization. Hiring a preparer does not move that promise.

Does the signer have to read every page?

The declaration says the signer examined the return, including accompanying schedules and statements. The IRS does not say how closely. Good practice is to see the exact final version and to hear from each owner of the review questions that the answers are true.

Who signs if the organization is a trust?

For a trust, the instructions say the authorized trustee or trustees must sign.

What if the usual signer leaves before the return is filed?

The instructions look at the filing date: the signer must be a current officer who is authorized to sign as of the date the return is filed. If your usual signer has left, the return needs a signature from a current officer. Check your bylaws or board minutes for who holds each office now.

This article is general education. It is not legal, tax or financial advice. State law and your organization's own documents can change the answer.

What to do next

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