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Writer's pictureTrent Foster

Donor Identification and Disclosure

Updated: Feb 4, 2019


donors, disclosures, redacting, Form 990, Schedule B, IRS Sec 527
Don't give away your donor identification!

Donors are precious supporters of your organization. You want to keep them happy and safe. When the wrong hands get a grasp of donor details, privacy can disappear and leave donors’ information hanging out for public misuse.


The IRS generally does not require your organization to disclose in the annual reporting Form 990, including Schedule B, the names or addresses of your contributors. Your application for exempt status does require the names and addresses of contributors.


Private foundations follow different regulations. The disclosure ruling on donor information does not apply to foundations or to political groups falling under the restrictions of IRS Sec. 527. Under this ruling, a tax-exempt political organization must report the name and address, occupation, and employer of any individual who donates a total amount of $200 or more during a calendar year on Schedule A of Form 8872. The IRS may also require exempt political organizations to file Form 990, including Schedule B. Political organizations must make these forms that include donor details accessible to the general public.


The data on your IRS Form 990 becomes public once you submit it. As a nonprofit organization you have the right to redact the information that identifies your donors, or let your contributors know that the disclosure requirement does not affect 990 filings more than three years old.


The federal tax law issues rules for disclosure of Form 990 and its schedules and attachments. These regulations provide suggestions for responding to any disclosures.


Below are summaries of federal disclosure laws and possible responses to requests.


Form 990 and Disclosures


Once you file your organization’s IRS Form 990, the information on the form and its accompanying attachments and schedules become public knowledge. The government mandates that your organization and the IRS furnish a copy of most of the content in the filed Form 990 if asked.


Nonprofit organizations in California submit completed Form 990s to the state Attorney General. Anyone can find details of an organization’s Form 990 on the Attorney General’s website. These disclosures relate to Form 990s that were due or filed during the three years prior to the request for disclosure.


If someone requesting to see your filed Form 990 appears at your major business site during your usual business hours, the law requires you to supply a copy that day. If you receive a written request in the mail, you have 30 days to come up with a copy of your organization’s Form 990.


Your organization may not charge a copying fee for in-person requests for copies of the documents. However, with a written request, you have seven days to notify the individual of total charges for copying each page and the postage fees.


Donor Identity not Subject to Disclosure


For decades, most nonprofits had to divulge donor names and amounts given by major supporters on Schedule B of Form 990.


The IRS does not ask nonprofits to openly reveal the names of their contributors. However, if your organization is a foundation or a political entity under IRC Section 527, you must publish donor identities.


These benefactor particulars appear on Form 990, Schedule B. These facts are excluded from basic disclosure requirements.


Your organization must redact and edit details in Schedule B before it files Form 990 for public viewing.


Disclosure Requests


If you receive a request to disclose information from your organization’s Form 990 and any of its schedules or attachments, complete the actions below before responding:

  • Redact all names, addresses, and other identifying data such as details of stock donations, property, or gift amounts from Schedule B of Form 990.

  • Decide the pre-paid fees for photocopying and shipping copies of requested items for a written request. Inform the requester of the total amount within seven days of receiving the written request.

  • Confer with legal guidance regarding the intended disclosure to prevent releasing information that could be legally withheld.

Get ready to fulfill each onsite request for copies of your organization’s Form 990 and its schedules and attachments. Have these copies on-hand at your facility. Include in these documents the redacted Schedule B that was due or filed within three years of the request. Train customer-facing staff to respond to these requests.


Protect your donors’ personal data from public eyes. When donors feel safe and secure, they are more inclined to stay involved and contribute to your cause.


If you have questions about when and why to redact donor personal information, keep in touch with our blog. We have ideas to share and solutions to management and organizational questions. If you have questions about any other not-for-profit industry topics, contact our not-for-profit team leader at trent@tbfosteraccounting.com.

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