The Treasury Department on April 23, 2026, announced that the IRS plans to revise Form 990, Return of Organization Exempt from Income Tax, to improve transparency and provide clearer reporting on certain activities carried out by certain IRC Section 501(c)(3) tax-exempt organizations.

Activities that will be subject to additional reporting on Form 990 include those related to government contracts, governments grants and fiscal sponsorship arrangements. The announcement doesn't specify what new questions the IRS will ask, nor what specific new information will need to be reported on Form 990.

Treasury and the IRS said they expect to publish proposed regulations and provide the public with an opportunity to comment before any changes to Form 990 are finalized.

This announcement stems from a series of congressional hearings, the most recent being a House Ways & Means Committee hearing on February 10, 2026, at which witnesses called for greater transparency of foreign donations, use of government grants, and fiscal sponsorships of tax-exempt organizations.

Implications

While unusual, it is not unprecedented for Treasury to initiate Form 990 revisions or to promulgate regulations mandating Form 990 reporting changes. Treasury's announcement is the latest in a series of calls for greater oversight and transparency of exempt organizations to combat perceived fraud and abuse, building on momentum from recent congressional hearings and Treasury announcements.

The IRS has the authority to make some or all of the Form 990 reporting changes referenced by Treasury without the promulgation of regulations under IRC Section 6033(b)(16), which says the IRS can request reporting of "such other information for purposes of carrying out the internal revenue laws as the Secretary may require." The IRS, however, does not make law or provide precedential guidance through the Form 990 or instructions; rather, Form 990 asks questions about compliance with existing law and Treasury/IRS guidance. Accordingly, any changes to Form 990 requiring the reporting of fiscal sponsorships — a term and concept not currently defined under federal tax law — would likely follow, rather than precede, final regulations on fiscal sponsorships. Due to the time required to propose and ultimately finalize regulations, it is unlikely that the IRS will make any of the changes referenced in the Treasury announcement soon.