2023 Form 990-EZ: IRS-Accurate Compliance Checklist
Why 2023 990-EZ Is Unique
Form 990-EZ for 2023 applies exclusively to exempt organizations (501©, 527, or 4947(a)(1) nonexempt charitable trusts) with gross receipts under $200,000 and total assets under $500,000 at year-end. No 2020–2021 stimulus-reconciliation or ARPA provisions apply to nonprofit returns. Restricted filers include private foundations, donor-advised fund sponsors, hospitals, Section 501 (c) (3) health insurers, and Section 512(b)(13) controlling entities, who cannot file Form 990-EZ.
Year-Specific Programs Applicable to 2023 990-EZ
No Economic Impact Payment reconciliation, American Rescue Plan expansions, unemployment-exclusion relief, or Section 6417 Inflation Reduction Act elective-payment elections apply to Form 990-EZ. This form addresses nonprofit tax-exempt organization reporting only; stimulus, tax credit, and income-related provisions apply exclusively to individual and business income tax returns.
Organizations filing for tax year 2023 must comply with standard exempt-organization reporting requirements, including disclosure of unrelated business income, political activities, and governance practices. However, they are not subject to individual or business tax provisions introduced under pandemic-era legislation.
Ten-Step Compliance Checklist
1. Verify Eligibility by Threshold
Confirm organization has gross receipts under $200,000 AND total assets under $500,000 at the end of the 2023 tax year (Part II, column B, line 25). Organizations that meet or exceed either limit must file Form 990. Exclude private foundations, donor-advised fund sponsors, hospitals, section 501(c)(29) health insurers, and controlling entities under 512(b)(13) with transfers to controlled entities. For 2023, organizations choosing the Form 990-N e-Postcard must have gross receipts of $50,000 or less. Those exceeding $50,000 but under $200,000 may file Form 990-EZ if their assets are under $500,000.
2. Determine Organization Type
Identify entity classification: 501(c)(3), other 501(c) subsection, 527 political organization, or 4947(a)(1) nonexempt charitable trust. If 501(c)(3), prepare to complete Part VI, questions 46 through 49b and 52, and complete the tables for lines 50 and 51, and attach Schedule A (Public Charity Status and Public Support). Part VI includes yes/no questions 46 through 49b and 52, not questions 47 through 52. Lines 50 and 51 are tables (not yes/no questions) for highest compensated employees and independent contractors. For 2023, all section 501(c)(3) organizations must provide explicit certification on line 52 that Schedule A was completed; failure to certify properly triggers completeness deficiency.
3. Gather Compensation and Revenue Documentation
Collect W-2/1099-NEC/1099-MISC forms for officers, directors, trustees, and employees (lines 12–13, Part IV); bank and investment statements for interest, dividends, rents, royalties (line 4); donation records (line 1); program-revenue documentation (line 2); membership-dues receipts (line 3); and asset-sale transaction records (lines 5a–5c, 7a–7c). Ensure Forms 1099-INT, 1099-DIV, and capital gains/losses records are available for investment income (line 4) and sale of assets (line 5c). For qualified disaster relief contributions, maintain separate records and report totals separately on line 1 if requested.
4. Report Unrelated Business Income Requirement
If gross income from unrelated trade or business activities totals $1,000 or more during 2023 (measured independently from total revenue), indicate “Yes” on line 35a. Either file separate Form 990-T (due the same date as 990-EZ) or provide a written explanation in Schedule O for “Yes” without Form 990-T filed. For 2023, ensure all unrelated business activities are appropriately documented and allocated between exempt and nonexempt functions. If unrelated business taxable income exists, report the total on Form 990-T, Part I, line 11. Organizations reporting unrelated business gross income of $1,000 or more must file Form 990-T separately and cannot report such income solely on Form 990-EZ.
5. Complete Gaming and Fundraising Threshold Test
If gaming revenue (line 6a) exceeds $15,000 gross, or combined fundraising event gross revenue and related contributions (line 6b combined with related line 1 contributions) exceed $15,000, prepare and attach Schedule G, Parts II and III (Fundraising Events and Gaming).
If the combined amount is $15,000 or below, Schedule G is not required. For 2023, ensure that all gaming and fundraising activities are adequately documented, including gross receipts, direct expenses, and net income calculations. Maintain separate records for gaming activities (line 6a) and fundraising events (line 6b) to accurately determine Schedule G attachment requirements.
6. Prepare Part II Balance Sheet
Enter beginning-of-year (column A) and end-of-year (column B) values: cash/savings/investments (line 22), land/buildings (line 23), other assets described in Schedule O (line 24). Calculate total assets (line 25) by summing lines 22–24 for each column. Identify and describe all liabilities in Schedule O (line 26). Calculate net assets (line 27) as line 25 minus line 26 for each column.
Verify line 27 column B equals Part I line 21 (net assets at end of year). For 2023, apply a consistent accounting method (cash, accrual, or other specified method) throughout the tax year. Ensure the balance sheet reconciles with the audited financial statements if the organization is required to submit audited financial statements.
7. Complete Part IV Officer and Compensation Table
List all officers, directors, trustees, key employees (including those not compensated). For each person, report name, title, average hours per week devoted to position, reportable compensation from Forms W-2/1099-NEC/1099-MISC (column c), health benefits and deferred compensation (column d), and estimated other compensation (column e). Add separate line items for the five highest compensated employees earning over $100,000 during 2023 (line 50) and the five highest compensated independent contractors earning over $100,000 (line 51), including the type of service and compensation amounts.
For 2023, ensure that all nonemployee compensation reported on Form 1099-NEC is included in Part IV compensation totals. Key employees are defined as any person who had reportable compensation of more than $150,000 from the organization and any related organizations and who meets specific responsibilities. If no compensation was paid, enter -0-. Ensure consistency between Part IV compensation and amounts reported on Form 990-EZ Part I, line 12 (salaries and employee benefits).
8. Complete Part VI for 501(c)(3) Organizations
Answer questions 46 (political campaign activities—if yes, prepare Schedule C, Part I); 47 (lobbying activities—if yes, prepare Schedule C, Part II); 48 (school status—if yes, attach Schedule E); 49a–49b (transfers to an exempt non-charitable related organization; identify if Section 527 is related); and 52 (certification of Schedule A completion). Line 46 (not 47) addresses political campaign activities. Line 47 addresses lobbying activities.
Correct sequence: 46, 47, 48, 49a–49b, and 52. All section 501(c)(3) organizations must prepare, complete, and attach Schedule A showing public charity status determination and public support calculation. For 2023, all section 501(c)(3) filers filing Form 990-EZ must provide explicit certification on line 52 that Schedule A was completed; failure to certify properly triggers a completeness deficiency.
9. Attach Required Schedules and Supplemental Information
Attach Schedule O for all questions requiring “Yes” responses that demand narrative explanation. If indoor tanning services were provided during 2023 (line 44c “Yes”), either file Form 720 quarterly or provide written explanation in Schedule O. If line 35a unrelated business income is “Yes” without accompanying Form 990-T filed, explain Schedule O. All section 501(c)(3) organizations must attach completed Schedule A. Include Schedule G if gaming or fundraising thresholds exceeded.
Attach Schedule B (Schedule of Contributors) if contributors gave $5,000 or more; Schedule B is filed with the IRS but is not publicly disclosed for most 501(c) organizations (except section 527 political organizations and private foundations).
Attach any other schedules indicated by Part V answers (for example, Schedule C, D, E, F, L, N as applicable).
10. Sign, Date, and Finalize Submission
Authorized officer signs and dates Part V declaration page (page 4). Print or type the signer’s name, title, date, and telephone number. If the paid tax preparer signs the prepared form, enters the preparer's tax identification number (PTIN), and includes the preparer firm EIN if applicable. Verify that the organization's legal name, EIN, beginning and ending tax year dates, and Form 990-EZ 2023 version are correct and match all schedules. For calendar-year 2023 filers, the filing deadline is May 15, 2024.
Request an automatic six-month extension to November 15, 2024, using Form 8868. Refer to the IRS "Where to File" page for the current submission procedures and addressing requirements for Form 990-EZ 2023. Assemble the return in the following order: Form 990-EZ core (pages 1 through 4), Schedule A, Schedule B, Schedule G (if applicable), Schedule L (if applicable), Schedule O (if applicable), and any required attachments.
Form-Specific Limitations
Private Foundation Exclusion: Private foundations and section 4947(a)(1) trusts treated as private foundations must file Form 990-PF, not Form 990-EZ, regardless of asset or revenue size.
Restricted-Filer Exclusion: Donor-advised fund sponsoring organizations, hospital operators, section 501(c)(29) nonprofit health insurers, and controlling organizations under section 512(b)(13) that engaged in transfers to controlled entities during 2023 must file Form 990, not Form 990-EZ, even if gross receipts and total assets fall below 990-EZ thresholds. Organizations with gross receipts of $200,000 or more, or total assets of $500,000 or more, must file Form 990 instead. Foreign organizations and domestic organizations outside the United States or its possessions are generally not eligible to file Form 990-EZ.
Lines Updated or Clarified for 2023
Interactive Help Icons (Form-Wide): Question-mark icons appear throughout Form 990-EZ when filed on the IRS platform. Clicking these icons triggers pop-up windows with clarifications specific to each field, assisting in accurate completion and reducing return-rejection risk. Prior year forms provided line-by-line and part-by-part guidance without embedded assistance. This function is a user interface enhancement for on-platform filing, practical as of 2023.
Schedule A Certification (Part VI, Line 52): All section 501(c)(3) filers submitting Form 990-EZ must explicitly certify on line 52 that they have completed Schedule A; failing to provide this certification correctly will result in a completeness deficiency. Prior-year instructions directed Section 501 (c) (3) organizations to attach Schedule A if required; completion was assumed when necessary. This feature is a required explicit yes/no response, reinforced for 2023.
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This checklist is for educational purposes only and does not constitute tax or legal advice. Always review official IRS instructions and consult a qualified professional for guidance.
