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Form 990 Schedule A: Public Charity Status and the Public Support Test

Sherman Hsieh

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Last updated: October 9, 2026 · Independent guide · We do not sell rankings or coverage.

Form 990 Schedule A is where a 501(c)(3) organization states why it is a public charity rather than a private foundation and, for most donor-funded charities, proves it with a five-year public support computation. An organization classified under section 170(b)(1)(A)(vi) must show that at least 33 1/3% of its total support came from the public, or at least 10% plus a facts-and-circumstances showing. A section 509(a)(2) organization uses a different test that counts program revenue but limits investment income.

What Schedule A requires, part by part

Part I asks you to check one box giving your reason for public charity status, and that box decides which other parts you complete.

Part II: the 170(b)(1)(A)(vi) test

Part II has five columns, one per year (2021 to 2025 on the 2025 form) plus a total in column (f). Lines 1 to 3 report contributions, tax revenues levied for you and free government services or facilities. Line 4 totals them, line 5 removes the excess over the 2% limit, and line 6 is public support.

Total support on line 11 adds line 4 back in full, plus gross investment income (line 8), net unrelated business income (line 9) and other income (line 10). Line 14 is line 6 divided by line 11, rounded to two decimals. Gross receipts from related activities go on line 12 and sit outside both sides of the fraction.

Line 16a is checked if line 14 is 33 1/3% or more, which qualifies the organization for 2025 and 2026. Line 16b uses last year’s percentage (line 15) and qualifies for 2025 only. Lines 17a and 17b do the same at 10% with a facts-and-circumstances explanation in Part VI.

The 10% facts-and-circumstances test

Treasury Regulations section 1.170A-9(f)(3) says an organization below one-third must meet a ten-percent-of-support requirement and an attraction of public support requirement, meaning “a continuous and bona fide program for solicitation of funds from the general public, community, or membership group,” or efforts to attract support from governmental units or other public charities. The regulation also weighs five factors, including the sources of support, a governing body representing the broad public interest and services provided to the public, which your Part VI narrative should address.

Part III: the 509(a)(2) test

Part III suits organizations with substantial program revenue. More than 33 1/3% of support must come from gifts, grants, contributions, membership fees and gross receipts from related activities. No more than 33 1/3% may come from gross investment income plus net unrelated business income from businesses acquired after June 30, 1975.

The limits differ from Part II. Line 7a removes all amounts received from disqualified persons, such as substantial contributors and board members, regardless of size. Line 7b removes related-activity receipts from any one person or government bureau that exceed the greater of $5,000 or 1% of line 13 for that year. Contributions from other donors are not capped. Organizations that fail Part II can try Part III and, if they qualify, check Part I line 10.

How the 2% excess-contribution limit works

For Part II, line 5 reports the portion of each individual’s, trust’s or corporation’s five-year contributions that exceeds 2% of line 11, column (f). Contributions from a donor and from related persons described in sections 4946(a)(1)(C) through (G), such as spouses, certain family members and controlled entities, are treated as made by one person.

The limit does not apply to governmental units or to other 170(b)(1)(A)(vi) publicly supported organizations. Under Treasury Regulations section 1.170A-9(f)(6)(v), a public charity or government grant that a donor earmarked for your organization is capped.

Illustrative example (constructed, not a real organization). A charity reports five-year contributions of $1,300,000 on line 1 and $200,000 of investment income, so line 11 total support is $1,500,000 and the 2% limit is $30,000.

Line 5 is $730,000, line 6 is $570,000, and the public support percentage is $570,000 / $1,500,000 = 38.00%, so the charity checks line 16a.

Now suppose the CPA reviews the county agreement and finds it pays for services the county itself needs. The instructions treat such a payment as gross receipts from a related activity on line 12, not support. Line 4 falls to $1,150,000, total support to $1,350,000, and the 2% limit to $27,000, which raises the foundation’s excess to $673,000 and the couple’s to $63,000. Public support becomes $414,000 / $1,350,000 = 30.67%, and the charity now depends on line 16b or the 10% test.

Who is exempt from the support computation

• Status by activity. Churches, schools, hospitals, medical research organizations, governmental units and agricultural research organizations (Part I lines 1 to 4, 6 and 9) skip Parts II and III.
• Supporting organizations. Line 12 filers complete Parts IV and V instead.
• The first five years. An organization in its first 5 tax years as a 501(c)(3) checks line 13 (Part II) or line 14 (Part III) and stops.

Deadlines and penalties

Schedule A is filed with Form 990 or 990-EZ, which is due on the 15th day of the 5th month after year end, with an automatic 6-month extension on Form 8868. For a calendar-year 2025 return, that was May 15, 2026.

The Form 990 instructions say the late-filing penalty “can also be charged if the organization files an incomplete return, such as by failing to complete a required line item or a required part of a schedule.”

The larger risk is reclassification. An organization that checks line 18 (Part II) or line 20 (Part III) and qualifies under no other Part I box is a private foundation for filing purposes from the start of that tax year, files Form 990-PF and becomes subject to the 1.39% excise tax on net investment income (IRS, September 11, 2026).

Records you must keep

The instructions ask you to keep four lists for your own records and not to file them, because Schedule A is open to public inspection:

1. The 2% donor list: each capped donor whose five-year total exceeds 2% of line 11, column (f).
2. The unusual grants list: for each year, the contributor, date, amount and a description of each grant excluded as unusual.
3. The disqualified persons list (Part III): name and total received each year from each disqualified person.
4. The line 7b list (Part III): each payer’s receipts by year and the excess over the limit.

Form 990 records generally must be kept at least 3 years from the due or filing date, but each Schedule A reuses four prior years, so keep donor-level detail longer.

What to set up in your systems to comply

Schedule A uses the same accounting method you check on Form 990, Part XII, line 1, and the prior-year columns should match last year’s Schedule A.

Donated services and donated use of facilities are excluded from line 1 even when GAAP records them. A pledge later written off is deducted from the year it was first reported.

Software support is uneven. Thomson Reuters documents a Schedule A tab in the UltraTax CS 990 Contributor Information window and a “Calculate Schedule A 2% limitation” checkbox that calculates Part II, Section A from contributor information instead of from the SchA, Part II & III screen. Foundant’s CommunitySuite has a Public Support Report that lists donors and takes a “Percent Exceeded” value you enter, such as 0.02 for 2%, though you supply the line 11 total yourself. Sage Intacct’s nonprofit Compliance dashboard “includes 990 reporting worksheets,” but its documentation does not mention Schedule A or public support. For most organizations, the practical setup is a donor CRM that holds donor type and household links (see our donor management software guide) and a ledger whose revenue accounts separate contributions, government contracts and program fees (see our nonprofit accounting software comparison). Our Form 990 preparation guide covers mapping the rest of the return.

How we researched this

We read the 2025 Instructions for Schedule A, the 2025 Schedule A form, Publication 557 (revised January 2025), Treasury Regulations section 1.170A-9, the Form 990 instructions and the IRS Schedule A filing tips index, all checked on October 9, 2026. We then reviewed vendor documentation from Thomson Reuters, Foundant and Sage Intacct, each of which sells the products described. We also read the top-ranking pages for this topic; none listed the donor and revenue data a system must hold.

Related guides

• Form 990-T: Filing Rules and Pulling UBTI From the Ledger
• Statement of Activities: Nonprofit Template and How-To
• Pledge Management Software for Nonprofits (2026 Guide)

Frequently asked questions

What happens if we fail the public support test for one year?

Passing on line 16a covers the current year and the next, and line 16b lets you qualify using last year’s percentage. If you fail both 33 1/3% lines, you can try the 10% facts-and-circumstances test or the 509(a)(2) test in Part III. Only if nothing on Schedule A applies do you become a private foundation for that tax year.

Do grants from private foundations count as public support?

Yes, but only up to 2% of five-year total support per foundation in Part II. Anything above that goes on line 5 and is removed from public support. Grants from governmental units and publicly supported charities are not capped unless a donor earmarked them for you.

Do new nonprofits have to complete the public support test?

Not on the filed return. For the first 5 tax years as a 501(c)(3), you check line 13 in Part II or line 14 in Part III and stop. The IRS recommends running the calculation privately each year so you know whether you will pass in year six.

What is an unusual grant on Schedule A?

It is generally a large gift from a disinterested person, attracted by your public nature, unexpected in amount and big enough to endanger your status. It is excluded from both public support and total support. You list the amount in Part VI and keep the donor’s name in your own records.

Sources

• IRS, Instructions for Schedule A (Form 990) (2025), checked October 9, 2026. irs.gov
• IRS, Schedule A (Form 990) 2025, form, no date shown. irs.gov
• IRS, Publication 557 (01/2025), Tax-Exempt Status for Your Organization, checked October 9, 2026. irs.gov
• IRS, Instructions for Form 990 (2025), checked October 9, 2026. irs.gov
• IRS, Form 990 filing tips: Schedule A, public support and public charity classification, June 28, 2026. irs.gov
• Treasury Regulations, 26 CFR 1.170A-9, Definition of section 170(b)(1)(A) organization, no date shown. law.cornell.edu
• IRS, About Form 8868, Application for Extension of Time To File an Exempt Organization Return, March 31, 2026. irs.gov
• IRS, Tax on net investment income (private foundations), September 11, 2026. irs.gov
• Thomson Reuters (vendor), Entering contributor information, UltraTax CS 990, no date shown. thomsonreuters.com
• Thomson Reuters (vendor), Calculate Schedule A limitation, UltraTax CS 990, no date shown. thomsonreuters.com
• Foundant Technologies (vendor), CommunitySuite Public Support Report, January 15, 2026. foundant.com
• Sage Intacct (vendor), Dashboards for nonprofit compliance, October 8, 2026. intacct.com

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Sherman Hsieh

CEO & Editor-in-Chief, Business-Software.com
Independent analysis of enterprise software — ERP, CRM and more

Sherman Hsieh is the founder, CEO, and editor-in-chief of Business-Software.com. He leads the site's independent, buyer-focused coverage of ERP, CRM, and other business systems, including vendor-neutral comparisons, pricing analysis, and implementation guidance. Before founding Business-Software.com, Sherman was an executive at Siebel ...