Key takeaways — Which Form 990 you file depends on gross receipts and assets, and it’s due the 15th day of the 5th month after your year ends. Miss it three years running and exemption is revoked automatically. Since January 2025, Utah nonprofits must also register with the state and upload that same 990 every year.
Most nonprofit boards understand they have to file something with the IRS each year. Fewer can say which form, and fewer still know that three missed filings ends the organization’s tax-exempt status without anyone at the IRS having to send a warning.
That gap has become more expensive in Utah. As of January 1, 2025, your Form 990 isn’t only a federal obligation — the state now wants a copy of it every year too, and the registration numbers many Utah nonprofits have carried for years stopped being valid.
Here’s what actually applies, and where organizations most often get caught.
Which Form 990 does your nonprofit file?
It comes down to size — gross receipts and total assets — with one exception for private foundations.
Two details trip people up.
“Or” is doing real work in that third row. A nonprofit with modest revenue but a paid-off building can land above the $500,000 asset threshold and owe a full Form 990 despite feeling like a small organization.
“Normally” has a specific meaning for the $50,000 test. Per the IRS, an organization’s gross receipts are normally $50,000 or less if it has existed one year or less and received $75,000 or less; existed one to three years and averaged $60,000 or less; or is at least three years old and averaged $50,000 or less over the preceding three tax years. It’s an average, not a single year — so one unusually good year doesn’t necessarily push you up a form, and one lean year doesn’t pull you down.
You can always file a more detailed return than required. A 990-N filer that wants the credibility of a full 990 in front of funders is free to file one. The IRS form-selection guidance covers the full matrix.
When is Form 990 due, and can you extend it?
The 15th day of the 5th month after your accounting period ends. For a calendar-year nonprofit, that’s May 15. For a June 30 fiscal year-end — common among organizations aligned to a school or grant calendar — it’s November 15.
Form 8868 gives you an automatic six-month extension. Automatic means exactly that: no explanation required, no approval to wait for. File it by the original due date and you’re extended.
But it does not work for Form 990-N. The IRS is blunt about this: “Form 8868 cannot be filed to extend the due date of a Form 990-N (e-Postcard).” That catches people out, because the e-Postcard is the easiest return in the series and the assumption is that anything this simple must be flexible. It isn’t — see the IRS extension guidance.
There’s no late-filing penalty on a 990-N. What there is — and this is the part that matters — is a clock.
What happens if you don’t file?
Three consecutive years of not filing, and tax-exempt status is revoked automatically.
Not “may be revoked.” Not “after a notice and an opportunity to respond.” The IRS revokes it as of the original due date of the third missed return, once that due date has passed.
A few things make this more dangerous than it sounds:
It applies to 990-N filers too. The smallest organizations, filing the simplest return, lose exemption on the same terms as a large one. In practice these are the organizations most at risk, because an all-volunteer board with turnover is exactly where an eight-question online form quietly stops being anyone’s job.
Revocation is retroactive, not forward-looking. The effective date is the original due date of that third return, not the day the IRS gets around to processing it.
Getting it back means reapplying. Reinstatement is a new application, with a fee, and the gap in exempt status has to be dealt with.
A timely extension protects you. If you file Form 8868 by the due date and then file by the extended date, exemption isn’t automatically revoked during that extension period.
It applies to 990-N filers too. The smallest organizations, filing the simplest return, lose exemption on the same terms as a large one. In practice these are the organizations most at risk, because an all-volunteer board with turnover is exactly where an eight-question online form quietly stops being anyone’s job.
Revocation is retroactive, not forward-looking. The effective date is the original due date of that third return, not the day the IRS gets around to processing it.
Getting it back means reapplying. Reinstatement is a new application, with a fee, and the gap in exempt status has to be dealt with.
A timely extension protects you. If you file Form 8868 by the due date and then file by the extended date, exemption isn’t automatically revoked during that extension period.
The pattern we see is rarely defiance. It’s a treasurer stepping down mid-year, a fiscal year-end nobody mapped to a deadline, or a board that assumed the bookkeeper handled it while the bookkeeper assumed the board did.
The Utah rule that changed on January 1, 2025
This is the one most Utah organizations we talk to haven’t caught up with.
Effective January 1, 2025, all domestic and foreign nonprofits doing business in Utah must register the entity with the Utah Division of Corporations and Commercial Code (DCCC) — and annually upload a copy of the nonprofit’s most recently filed Form 990, 990-EZ, 990-N, or 990-PF.
Two consequences worth sitting with:
Your 990 is now a state compliance document, not just a federal one. Whatever you file with the IRS gets uploaded to the state as part of your annual report. A late or missing 990 is no longer only an IRS problem.
Your old registration number probably doesn’t work. Per the Utah Division of Consumer Protection, the previous DCP registration numbers ending in -CHAR are no longer valid. New entity numbers assigned by DCCC end in -0140 or -0141. If your organization is still carrying a -CHAR number on grant applications or your website, that’s stale.
The upside is that the process got simpler. The old seven-page DCP application, the statement of functional expenses, and the supporting documentation are gone — the Form 990 does that work now. Existing organizations upload it during their annual report filing; brand-new nonprofits without a filed 990 yet upload one when they file their first annual report.
What your bookkeeping has to produce to make any of this work
A Form 990 is only as good as the records behind it, and nonprofit books ask for things a small-business chart of accounts usually doesn’t carry.
Functional expense allocation. The 990 wants expenses split across program services, management and general, and fundraising. If your books only track expenses by type — rent, salaries, supplies — someone has to reconstruct that split at year-end, usually under deadline pressure and usually with less precision than doing it monthly.
Restricted vs. unrestricted funds. Money that came with donor conditions has to be tracked separately from money that didn’t. Blending them is the single most common cleanup we’re asked to fix, and it’s the one that most often surprises a board — because the bank balance looked fine.
Grant-level detail. Funders ask what their specific dollars bought. Books structured only around the whole organization can’t answer that without a reconstruction exercise.
Board-usable reporting. A treasurer’s report that a volunteer board can actually read and act on is a different document from a P&L export.
Get the structure right in QuickBooks up front and the 990 becomes a reporting exercise. Get it wrong and every year ends in a cleanup.
Does your nonprofit need an audit?
This is a separate question from the 990, and conflating the two causes a lot of unnecessary worry.
Filing a Form 990 does not mean you need an audit. Audits get triggered by something else — a grant agreement, a bond covenant, the level of federal awards an organization spends in a year, or a funder’s own policy. Plenty of small nonprofits never need one. An organization with significant federal awards may have no choice.
There’s also a middle ground people don’t know exists: a review or a compilation provides less assurance than an audit at meaningfully lower cost, and is often exactly what a funder will accept. Our guide to audit, review, and compilation services walks through which level fits which situation.
If a funder is asking for “audited financials,” it’s worth confirming what they actually require before commissioning the most expensive option.
Frequently Asked Questions
Which Form 990 does my nonprofit have to file?
It depends on size. Gross receipts normally $50,000 or less can file Form 990-N, the e-Postcard. Gross receipts under $200,000 and total assets under $500,000 can file Form 990-EZ. Gross receipts of $200,000 or more, or total assets of $500,000 or more, means the full Form 990. Private foundations file Form 990-PF regardless of size.
When is Form 990 due?
The 15th day of the 5th month after your accounting period ends. For a calendar-year nonprofit that’s May 15. Form 8868 gets you an automatic six-month extension, but it does not apply to Form 990-N.
Can I get an extension on Form 990-N?
No. The IRS states plainly that Form 8868 cannot be filed to extend the due date of a Form 990-N. This surprises people, because the e-Postcard is the simplest return in the series. There’s no penalty for filing 990-N late, but the three-year clock toward automatic revocation still runs.
What happens if a nonprofit doesn’t file Form 990?
Miss the filing for three consecutive years and tax-exempt status is revoked automatically, effective as of the original due date of the third missed return. It’s automatic — no notice is required — and it applies to the smallest 990-N filers just as it does to large organizations.
Do Utah nonprofits have to file anything with the state?
Yes. Effective January 1, 2025, all domestic and foreign nonprofits doing business in Utah must register the entity with the Utah Division of Corporations and Commercial Code and annually upload a copy of the most recently filed Form 990, 990-EZ, 990-N, or 990-PF. The old DCP registration numbers ending in -CHAR are no longer valid.
Does my nonprofit need an audit?
An audit is a separate question from the Form 990 filing obligation. Audits are typically triggered by grant agreements, bond covenants, federal award spending, or a funder’s own policy rather than by the 990 itself. Many small nonprofits never need one; a nonprofit with significant federal awards may have no choice.
If your fiscal year is closing, your treasurer just changed hands, or nobody is certain which 990 you’re supposed to be filing, that’s worth an hour before it becomes a deadline. FJ & Associates works with Utah nonprofits on annual filings, fund accounting structure, and the assurance levels funders ask for — including low-income housing and assisted-housing organizations, where the compliance layer runs deeper than the 990. Start a conversation, or call (801) 927-1337.
This article is general information, not tax or accounting advice. Tax rules change and depend on your specific situation — consult a licensed CPA before acting. Federal thresholds reflect IRS guidance and Utah requirements reflect Division of Consumer Protection guidance as published at the time of writing.
Author | Missy Dennis, CPA | Tax Partner | FJ & Associates, PLLC | Kaysville, Utah
Missy holds a Master of Accounting from the University of Utah and is a licensed Certified Public Accountant with more than twenty years of public accounting experience. Nonprofit accounting and low-income housing tax credits are among her core specialisms, alongside estate and trust taxation and audit and consulting services. FJ & Associates has long-standing experience across the assisted housing, HUD, USDA-RD, tax credit, and nonprofit sectors.
