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Form 990 Schedule B: Reporting Contributors and Keeping Donor Data Ready

Sherman Hsieh

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

Form 990 Schedule B is the IRS Schedule of Contributors: it lists each donor who gave $5,000 or more in money or property during the tax year, with the amount and whether the gift was cash, payroll or noncash. A 501(c)(3) public charity that meets the 33 1/3% public support test under sections 509(a)(1) and 170(b)(1)(A)(vi) lists only donors whose gifts exceed the greater of $5,000 or 2% of the contributions on Form 990, Part VIII, line 1h. Contributor names and addresses are removed from the copy the public sees for most filers, but the IRS copy must be complete and must reconcile to your revenue.

What Schedule B requires

The instructions define contributions broadly as “contributions, grants, bequests, devises, and gifts of money or property, whether or not for charitable purposes.” They exclude “fees for the performance of services.” A contributor can be an individual, fiduciary, partnership, corporation, association, trust or exempt organization. Organizations classified under sections 509(a)(2), 170(b)(1)(A)(iv) and 170(b)(1)(A)(vi) must also list governmental units as contributors, which means a large government grant reported on Part VIII, line 1e usually appears on Schedule B.

To decide whether a donor reaches $5,000, the instructions say to “include all separate and independent gifts that are $1,000 or more to determine a contributor’s total contribution.” Gifts under $1,000 can be disregarded. You must use the same accounting method you checked on Form 990, Part XII, line 1, and an accrual-method filer that reports a pledge of noncash property must count it toward the threshold even if the property has not arrived.

Column (d) matters for data design. “Person” is a cash gift that came directly from the contributor. “Payroll” applies when an employer forwards employee gifts, and you report only the employer’s name and the total unless you know an individual employee gave enough to be listed separately. “Noncash” covers any property other than cash and sends you to Part II. Securities sold immediately are reported at net proceeds plus broker fees.

The instructions say to identify a donor as “anonymous” only if the organization does not know the donor’s identity.

The special rule for 509(a)(1) and 170(b)(1)(A)(vi) organizations

A 501(c)(3) organization that shows on Schedule A, Part II, that it met the 33 1/3% support test for the current or prior year, or that checks the first-five-years box, lists only contributors whose gifts of $5,000 or more exceed 2% of Form 990, Part VIII, line 1h, column (A). The IRS example uses $700,000 of contributions, so the threshold is the greater of $5,000 or $14,000, and a donor who gave $11,000 is not listed.

Two points cause confusion. First, the special rule is tied to the 33 1/3% test only. An organization that qualifies through the 10% facts-and-circumstances test or under 509(a)(2) in Part III of Schedule A uses the general $5,000 rule. Second, the Schedule B 2% is measured against one year of contributions on line 1h, while the Schedule A 2% limit is measured against five years of total support. Our Form 990 Schedule A guide covers the public support computation.

Illustrative example (constructed, not a real organization). A 170(b)(1)(A)(vi) charity that passed the 33 1/3% test reports $1,800,000 on Part VIII, line 1h. Its Schedule B threshold is the greater of $5,000 or $36,000.

Under the special rule this charity lists three contributors. Under the general rule it would list all five.

Who is exempt, and who reports amounts without names

• Organizations with no reportable contributor. They answer “No” on Part IV, line 2 (or check the box on Form 990-EZ or 990-PF) and do not attach the schedule.
• Exempt organizations other than 501(c)(3) and 527 organizations. Under Treasury Decision 9898, published in the Federal Register on May 28, 2020, these organizations, such as 501(c)(4), (c)(5) and (c)(6) groups, enter “N/A” for names and addresses in Part I, column (b). They still report amounts and, in the words of the decision, must “maintain the names and addresses of their substantial contributors in their books and records” so the IRS can request them.

What the public copy shows

Schedule B is fully open to public inspection for Form 990-PF filers and section 527 political organizations. For every other Form 990 or 990-EZ filer, the instructions say “the names and addresses of contributors aren’t required to be made available for public inspection.” Amounts and noncash descriptions remain public unless they clearly identify the contributor. Never enter Social Security numbers.

The IRS page on public disclosure confirms that “with the exception of private foundations, an exempt organization is not required to disclose the name and address of any contributor.” Annual returns must be available for three years from the later of the due date, including extensions, or the filing date. Your tax software should produce a separate public inspection copy. In UltraTax CS 990, for example, Thomson Reuters documents a “Do not disclose contributor name and address information” checkbox on the Contributor Information tab for suppressing those fields.

States are a separate question. The IRS tells filers not to attach Schedule B to state filings unless the state specifically requires it. On July 1, 2021, the Supreme Court held in Americans for Prosperity Foundation v. Bonta that “California’s blanket demand for Schedule Bs is facially unconstitutional.” Check each state charity registration where you file before sending the unredacted schedule.

Deadlines and penalties

Schedule B is filed with the return: the 15th day of the 5th month after year end, or May 15 for a calendar-year filer, with an automatic 6-month extension on Form 8868. Form 990 returns must be filed electronically.

The 2025 Form 990 instructions set the organization penalty for a late or incomplete return at $25 a day, up to the lesser of $13,000 or 5% of gross receipts. For organizations with gross receipts above $1,309,500, it is $130 a day, up to $65,000 per return. The instructions add that missing or incomplete required schedules may lead the IRS to contact you and can result in a penalty. Separately, a person who fails to provide a requested public inspection copy faces $20 a day, up to $10,000 per annual return.

Records you must keep

• Donor detail behind each listed contributor: every gift of $1,000 or more, its date, amount, type and the receipt or acknowledgment you issued.
• Noncash support: appraisals, brokerage confirmations showing sale proceeds and fees, and the valuation method used for Part II.
• The threshold workpaper: line 1h, the 2% figure and the Schedule A line showing you passed the 33 1/3% test, if you used the special rule.
• Names and addresses for non-501(c)(3) filers that enter “N/A”, kept so the IRS can request them.

The Form 990 instructions require records that support income to be kept for at least 3 years from the later of the due date or the filing date. Schedule A reuses four prior years of donor data, so keep donor-level detail longer.

What to set up in your systems: running the contributor report so it ties to Part VIII

Schedule B is built from donor-level data, which usually lives in the donor CRM, while Part VIII, line 1h comes from the general ledger. A workable year-end routine has five steps.

1. Lock the population. Run the contribution revenue accounts from the ledger for the fiscal year, using the same cash or accrual basis as Part XII, line 1. This total, after the adjustments below, is line 1h.
2. Run the CRM gift report by legal donor. Filter to hard credits only, gift date within the fiscal year, gifts of $1,000 or more, and group by the donor record. Exclude soft credits and tribute credits, which double count the same dollars.
3. Add donors who are not in the CRM. Government grants and some foundation grants are often booked only in fund accounting. Pull them from the grants register.
4. Reconcile the totals. Explain every difference between the CRM total and line 1h, as in the illustration below.
5. Apply the threshold and classify. Filter to $5,000 or the 2% figure, then assign Person, Payroll or Noncash and prepare Part II from the in-kind log.

Illustrative reconciliation (constructed figures).

A few fields make this routine repeatable. In the CRM, keep a donor type (individual, corporation, foundation, governmental unit, donor-advised fund sponsor), a payroll-gift flag with the employer, and a noncash flag with valuation. A donor-advised fund is owned and controlled by its sponsoring organization under section 4966(d)(2), so record the sponsor as the hard-credit donor and the advisor as a soft credit. In the ledger, keep separate revenue accounts for government grants, in-kind gifts, event revenue and membership dues so the Part VIII lines map directly. Our donor management software guide compares CRMs on these fields.

Tax preparation software then takes the list. UltraTax CS 990 has a Contributor Information window with tabs for contributor names and addresses, cash and noncash contributions, and the Part III details for 501(c)(7), (8) and (10) organizations. It holds up to 999 contributors per client, and its documentation says it “marks the correct rule(s) based on IRS requirements and your entries,” including the special rule when Schedule A, Part II, line 14 exceeds 33 1/3%. Its documentation does not describe an automatic 2% calculation, so check the threshold yourself. Our Form 990 preparation guide covers mapping the rest of the return from your accounting system.

How we researched this

We read the Instructions for Schedule B (Rev. December 2024), the 2025 Instructions for Form 990, Treasury Decision 9898, the IRS public disclosure pages and the Supreme Court’s opinion in Americans for Prosperity Foundation v. Bonta, all checked on October 9, 2026. We reviewed Thomson Reuters documentation for UltraTax CS 990; Thomson Reuters sells that product. We also read the top-ranking pages for this search, from Tax990 and TaxBandits (both e-file vendors) and Jones & Roth CPAs.

Related guides

• Form 990 Schedule A: The Public Support Test Explained
• How to Record In-Kind Donations: Entries and ASU 2020-07
• Form 990-T: Filing Rules and Pulling UBTI From the Ledger

Frequently asked questions

Do 501(c)(3) organizations still have to report donor names on Schedule B?

Yes. Treasury Decision 9898 removed the name and address requirement only for exempt organizations other than 501(c)(3) and 527 organizations. A 501(c)(3) reports names and addresses on the copy filed with the IRS. The names and addresses are withheld from the public inspection copy.

Do government grants go on Schedule B?

For organizations classified under 509(a)(2), 170(b)(1)(A)(iv) or 170(b)(1)(A)(vi), yes. The instructions say these organizations must report governmental units as contributors. A government payment for services the agency itself receives is a fee, not a contribution, and is not reported.

Is the Schedule B 2% the same as the Schedule A 2% limit?

No. The Schedule B special rule uses 2% of one year’s contributions on Part VIII, line 1h. The Schedule A limit uses 2% of five years of total support on Part II, line 11, column (f).

Should we send Schedule B to our state charity regulator?

Only if the state specifically requires it, according to the IRS instructions. After the Supreme Court’s 2021 decision in Americans for Prosperity Foundation v. Bonta, California could no longer demand Schedule B from all charities. Review each state’s current registration instructions before you file.

Sources

• IRS, Instructions for Schedule B (Form 990) (Rev. December 2024), page updated April 30, 2026. irs.gov
• IRS, About Schedule B (Form 990, 990-EZ, or 990-PF), March 31, 2026. irs.gov
• IRS, Instructions for Form 990 (2025), no date shown, checked October 9, 2026. irs.gov
• IRS, Public disclosure and availability of exempt organizations returns and applications: documents subject to public disclosure, June 28, 2026. irs.gov
• IRS, Public disclosure and availability of exempt organizations returns and applications: penalties for noncompliance, June 28, 2026. irs.gov
• IRS, Instructions for Schedule A (Form 990) (2025), no date shown, checked October 9, 2026. irs.gov
• IRS, About Form 8868, Application for Extension of Time To File an Exempt Organization Return, March 31, 2026. irs.gov
• Treasury Decision 9898, Guidance Under Section 6033 Regarding the Reporting Requirements of Exempt Organizations, 85 FR 31959, May 28, 2020. govinfo.gov
• Supreme Court of the United States, Americans for Prosperity Foundation v. Bonta, No. 19-251, July 1, 2021. supremecourt.gov
• 26 U.S. Code section 4966, Taxes on taxable distributions (donor advised fund definition), no date shown. law.cornell.edu
• Thomson Reuters (vendor), Entering contributor information, UltraTax CS 990, no date shown. thomsonreuters.com
• Thomson Reuters (vendor), Schedule B general and special rules, UltraTax CS 990, no date shown. thomsonreuters.com
• Thomson Reuters (vendor), Create a public inspection copy PDF, UltraTax CS 990, no date shown. thomsonreuters.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 ...