By November, most nonprofit leaders are working on year-end fundraising, next year’s budget, and the programs already underway. Returning to last year’s financial records can feel like unfinished business that should have been settled months ago.
If your organization requested a Form 990 extension, however, the final review deserves time on the calendar. The numbers may be nearly complete while questions about restricted contributions, board policies, or a missing schedule remain unresolved.
For calendar-year nonprofits with a valid six-month extension, the deadline to file the 2025 Form 990 is November 16, 2026. November 15 falls on a Sunday, moving the deadline to the next business day. Organizations with a different fiscal year-end should confirm their own filing date.
The priority now is to resolve the items that could leave the return incomplete, inconsistent, or difficult to support.
Confirm The Extension And The Return Being Filed
Before reviewing the draft, locate the filed Form 8868 and its acceptance confirmation or other proof of timely filing. Confirm that the extension covers the correct organization, employer identification number, tax period, and return.
An extension for Form 990 does not automatically extend a separate Form 990-T filing obligation. It also generally does not extend the time to pay tax. If your organization has unrelated business income or another separate filing requirement, ask your preparer to confirm its status.
The IRS allows a single automatic six-month extension for eligible returns. Form 990-N cannot be extended. These distinctions are addressed in the IRS instructions for Form 8868.
This article focuses on the full Form 990. Organizations filing Form 990-EZ or Form 990-PF should use the requirements specific to those returns.
Make Sure The Return Uses The Final Financial Records
A common source of last-minute problems is a return prepared from financial statements that were later adjusted.
If an outside accountant completed year-end work after the original records went to the tax preparer, confirm that all final entries reached the return. Changes to pledges receivable, accrued expenses, investment balances, or net assets can affect several sections at once.
Review the draft alongside the final trial balance and financial statements. Pay particular attention to:
- Beginning balances that do not agree with the prior-year return.
- Contributions or grants classified differently across reports.
- Investment activity, donated property, and other noncash items.
- Differences between financial statement totals and Form 990 amounts that need a documented reconciliation.
The figures will not always match line for line because financial statement presentation and Form 990 reporting can differ. Those differences should be understood and supported.
Also look at how expenses are divided among program services, management and general, and fundraising. Shared salaries, occupancy costs, and technology expenses should follow a reasonable, documented allocation method. A percentage carried forward from last year may no longer reflect how staff and resources were used.
Revisit Restricted Net Assets And Grant Agreements
A bank balance does not tell you how much money is available for general operations. Some of that cash may be subject to donor restrictions that remain in effect.
For organizations reporting under nonprofit accounting standards, review the year-end balances of net assets with and without donor restrictions. Trace significant restricted gifts and grants to their agreements, then confirm whether the applicable purpose or time restrictions were satisfied.
A board-designated reserve is different from a donor-restricted contribution. The board’s decision to set money aside does not, by itself, create a donor restriction. The Form 990 instructions specifically distinguish these balances.
Grant agreements deserve a separate look when the accounting treatment is unclear. A donor restriction and a condition affecting when a contribution is recognized are different issues. An award letter or cash receipt alone may not settle the treatment.
Compare grant reports with the underlying accounting records, particularly when reports cover a different period than the organization’s tax year. Differences may be appropriate, but the finance team should be able to explain them. Filing Form 990 does not replace a report required by a funder.
Read The Governance Answers Against What Actually Happened
Part VI of Form 990 is easy to underestimate. Its questions cover governing body practices, conflicts of interest, compensation procedures, and other matters that may require information outside the accounting department.
Have someone familiar with the board’s activities review these answers.
For the 2025 return, a policy adopted in fall 2026 generally does not establish that the organization had that policy during 2025. The instructions specify the relevant timing for each question. Current improvements should not be used to rewrite the organization’s history.
Review board and authorized committee records for significant decisions, including compensation approvals, related-party arrangements, and major transactions. Check whether meetings and written actions were documented within the applicable timeframe.
For the Form 990 governance question, the IRS generally treats documentation as contemporaneous if it is completed by the later of the next meeting or 60 days after the meeting or written action. Reconstructing minutes shortly before filing does not necessarily satisfy that standard.
The return also asks whether a complete copy was provided to all voting members of the governing body before filing and requires a description of the review process. Having the treasurer review a draft is not the same as providing the complete return to every voting board member.
Answer according to the process actually followed. Form 990’s disclosure questions should not be confused with a blanket federal requirement that every listed governance policy be adopted.
Review Schedule B Before The Final Draft
Schedule B, Schedule of Contributors, often requires information held in the donor database rather than the general ledger.
Its general reporting rule covers contributors giving $5,000 or more during the tax year, subject to the detailed instructions and applicable exceptions. Certain qualifying public charities can use a special rule involving a 2% threshold. That rule is not available to every nonprofit.
Ask the preparer to confirm the rule that applies to your organization, then reconcile the donor information used for the schedule with the contribution revenue reported on the return.
Pay attention to multiple gifts from the same contributor, noncash contributions, and differences between donor records and accounting records. For accrual-basis organizations, recognized pledges may also affect the analysis.
Confidentiality requires care, too. For most organizations filing Form 990 or 990-EZ, contributor names and addresses generally do not have to appear in the public inspection copy. Different rules apply to private foundations and certain political organizations.
Prepare the public copy deliberately rather than assuming either that all of Schedule B is public or that the entire schedule can always be withheld. The IRS Schedule B instructions explain the reporting and disclosure rules.
Check Donor Acknowledgments Without Confusing The Deadlines
Donor acknowledgments are not ordinarily attached to Form 990, but the filing review is a useful opportunity to identify gaps in contribution records.
A donor claiming a deduction for a contribution of $250 or more generally needs a contemporaneous written acknowledgment. It should include the cash amount or a description of donated property, along with the required statement about goods or services provided in return.
For noncash gifts, the organization generally describes the property rather than assigning the donor’s deductible value. The IRS outlines the required elements in its guidance on written acknowledgments.
An acknowledgment that simply says “thank you for your support” may be missing necessary language.
The Form 990 extension does not extend the donor’s substantiation deadline. If an acknowledgment was omitted or incorrect, address it promptly with the preparer. A late replacement should not be assumed to cure every deduction issue.
Look Beyond The Main Form For Missing Disclosures
The checklist in Part IV determines which additional schedules are required. Review it against the organization’s actual activities rather than copying last year’s answers.
For example, grants made to others, noncash contributions, fundraising events, related organizations, or transactions involving interested persons may trigger additional reporting.
Public charities should also review Schedule A and any applicable public support calculation. A significant change in funding sources can matter even when total revenue looks healthy.
Schedule O deserves an editorial review. Explanations should answer the relevant question and agree with the rest of the return. Program descriptions should reflect the reporting year, including meaningful changes in services or activities.
Compensation reporting should receive similar attention. Confirm the required officers and other individuals are included, and review whether compensation from related organizations must be reported.
These are areas where a return can appear complete while still omitting information the IRS expects.
Leave Time For Signatures And Electronic Acceptance
The filing process is not finished when the draft is approved.
Arrange for the authorized signer to review the final return and complete the required electronic filing authorization before the deadline. Confirm that the preparer has submitted the return and received an IRS acceptance acknowledgment. A transmission receipt and an acceptance acknowledgment are different records.
Keep the filed return, required schedules, authorization, acceptance confirmation, and supporting reconciliations together.
Check state charitable registration and reporting obligations separately. A federal extension does not automatically resolve every state requirement, and grant reporting deadlines remain governed by the applicable agreements.
A careful review cannot guarantee that an organization will never receive IRS correspondence. It can help prevent avoidable questions caused by missing schedules, inconsistent figures, or incomplete explanations.
Frequently Asked Questions
Which Nonprofits Have A November 16, 2026 Form 990 Deadline?
The date generally applies to organizations with a December 31, 2025 year-end that obtained a valid six-month filing extension. Fiscal-year organizations should calculate their deadline using their own year-end and confirm any applicable relief.
Can We Request Another Form 990 Extension?
The standard Form 8868 process allows a single six-month extension. Organizations should not plan on another routine extension. Separate IRS relief may apply in specific circumstances.
Does The Board Have To Approve Form 990 Before Filing?
Form 990 asks whether the complete return was provided to all voting governing body members before filing and requires a description of the review process. That is different from a universal IRS requirement for formal board approval. Your bylaws, policies, or other applicable requirements may call for additional review or approval.
Do We Need To Attach Board Minutes And Donor Letters?
These records are generally retained as support rather than routinely attached to Form 990. The return must still include all required schedules and explanations. Your preparer should identify any documents needed to support the answers.
Support For Your Nonprofit’s Final Filing Review
Prudent Accountants works with nonprofits in Minneapolis, the Twin Cities, and the Dallas–Frisco area on accounting, tax preparation, and financial reporting. If your extended Form 990 still has unresolved balances, missing records, or disclosure questions, contact us to discuss the remaining work before filing.
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