While proposed regulations have not yet been released, early indications suggest that future updates could expand reporting expectations related to government grants and contracts, fiscal sponsorship arrangements, and organizational governance and financial management practices.

Although no effective date has been announced, nonprofit organizations may benefit from taking a proactive approach. This includes reviewing governance policies, assessing the consistency and accuracy of financial and operational data, evaluating any fiscal sponsorship or public funding arrangements, and confirming that recent Form 990 disclosures accurately reflect organizational activities and funding sources.

For additional background on the Treasury Department’s transparency initiative and anticipated Form 990 updates, we encourage you to review recent coverage from the Journal of Accountancy:
IRS to Update Form 990 Amid Transparency Push for Nonprofits

As more formal guidance is released, we will continue to share updates. In the meantime, please contact your Nisivoccia representative if you have questions about how potential changes may affect your organization.