Nonprofit Accounting
Nonprofit Management
Form 990 Schedule O: What to Write in the Supplemental Information Narrative
Last updated: October 10, 2026 · Independent guide · We do not sell rankings or coverage.
Form 990 Schedule O is the supplemental information schedule where you write the narrative explanations that specific Form 990 questions call for, identified by part and line number. Every organization that files Form 990 must file it, because Part VI line 11b (how the return was reviewed) and line 19 (how governing documents, the conflict of interest policy and financial statements are made public) always need an answer there. Other entries are triggered by your answers, such as a “Yes” on line 12c or an amount on Part XI line 9. Below are the triggers, sample wording and the records to draft from.
The rule in brief
- Who it applies to: all Form 990 filers, and Form 990-EZ filers whose answers call for an explanation.
- Minimum requirement: narrative answers to Form 990 Part VI lines 11b and 19, every year.
- Triggered entries: specific answers in Parts III, V, VI, VII, IX, XI and XII.
- Format: label each response by part and line, in form order, with no Social Security numbers, because the schedule is public.
- Key dates: filed with Form 990, due the 15th day of the 5th month after year end, extendable on Form 8868.
- Official source: IRS Instructions for Schedule O (Form 990), revised 12/2024, a continuous-use revision for tax year 2024 and later. We checked it on October 10, 2026.
What Schedule O requires
The IRS says to use Schedule O “rather than separate attachments” for narrative answers to specific Form 990 or 990-EZ questions. Complete the core-form line first, then write the explanation labelled with its part and line.
Schedule O does not supplement the other schedules. Each other schedule has its own supplemental part, and the late-filing reasonable-cause statement goes in a separate statement.
In Parts III and V through XII you also check the box in the part’s heading when Schedule O contains information about that part.
Form 990 lines that require a Schedule O explanation
The table below condenses the list in the Schedule O instructions for the lines most organizations meet. Part VI drives most of the work.
| Part and line | Trigger | What the narrative must cover | Record to draft from |
|---|---|---|---|
| Part VI, 1a | Unequal voting rights, or an executive committee with broad authority | Material voting differences; committee composition, non-board members, scope of authority | Bylaws, committee charter |
| Part VI, 2 to 7b | “Yes” | Relationships, management company, significant document changes, asset diversions, member and appointment rights | Annual questionnaires, contracts, amended bylaws, incident file |
| Part VI, 8a, 8b, 10b | “No” | Practices for documenting meetings; how chapters are kept consistent with exempt purposes | Minutes log with approval dates |
| Part VI, 11b | Always | Who reviewed the return, when, and how thoroughly | Distribution log, meeting minutes |
| Part VI, 12c | “Yes” | Covered persons, who determines and reviews conflicts, recusal rules | Conflict of interest policy, disclosure statements |
| Part VI, 15a, 15b | “Yes” | Compensation-setting process, positions covered, year last performed | Compensation committee minutes, comparability data |
| Part VI, 18 and 19 | “Other” box on 18; line 19 always | How documents are made available to the public | Website posting log, request log |
| Part IX, 11g and 24e | Amount over 10% of line 25 | Type and amount of each expense included | General ledger mapping report |
| Part XI, 9 | Any amount | Itemized other changes in net assets | Net asset roll-forward |
| Part XII, 1, 2c, 3b | Method change or “Other”; change in audit oversight; “No” on 3b | The change, the new oversight process, or why a required audit has not happened | Audit committee charter, engagement letters |
Parts III, V and VII have further triggers, such as new or discontinued program services on Part III lines 2 and 3. The full list is in the Schedule O instructions.
Sample wording for the Part VI governance lines
The IRS does not publish model language. The samples below are an illustration for a fictional organization, so replace every name, date and body with what your own records show.
Line 11b: Form 990 review process
The line 11b instructions ask for “specifics about who conducted the review, when they conducted it, and the extent of any such review.” If nobody reviewed it, the IRS asks you to enter “No review was or will be conducted.”
Illustration: “Form 990, Part VI, line 11b. The organization’s outside CPA firm prepared the return from the audited financial statements and the general ledger. The Chief Financial Officer reviewed the full draft, including all schedules. The Finance and Audit Committee reviewed the draft with the CPA at its meeting on April 22, 2026, and a complete copy of the final return was posted to the board portal for all voting directors before it was filed.”
Line 12c: monitoring conflicts of interest
Cover who the policy covers, who decides whether a conflict exists, who reviews actual conflicts, and restrictions on the conflicted person.
Illustration: “Form 990, Part VI, line 12c. The conflict of interest policy covers directors, officers and key employees, who complete a written disclosure statement each year and update it when circumstances change. The Governance Committee reviews the statements and determines whether a conflict exists. The board, excluding any interested director, reviews actual conflicts and approves or rejects the transaction. An interested person may not attend deliberations or vote on the matter, and the minutes record the recusal.”
Line 19: documents available to the public
State whether and how your governing documents, conflict of interest policy and financial statements were available to the public. If none were, enter “No documents available to the public.”
Illustration: “Form 990, Part VI, line 19. The organization’s articles of incorporation, bylaws, conflict of interest policy and audited financial statements are available on request from the main office and are posted on the organization’s website.”
Part XI and Part XII narratives
Part XI, line 9: other changes in net assets
Line 9 covers changes in net assets not listed on lines 5 through 8, such as losses on uncollectible pledges, refunds of contributions, and reversal of grant expenses. Itemize them on Schedule O. Line 10 must then equal Part X, line 32, column (B).
Illustration: “Form 990, Part XI, line 9. Other changes in net assets: write-off of uncollectible pledges receivable, ($18,500); refund of a restricted contribution returned to a donor, ($12,000); total, ($30,500).” The amounts here are invented for the example; each figure in your narrative should tie to a ledger account or a line in your net asset roll-forward.
Part XII, lines 1, 2c and 3b
Explain a change in accounting method or an “Other” method (line 1), a change in the committee that oversees the audit and selects the auditor (line 2c), or a “No” on line 3b, meaning a required Single Audit under 2 CFR Part 200, Subpart F was neither completed nor in progress.
Illustration for line 2c: “Form 990, Part XII, line 2c. During the year the board created a separate Audit Committee, which now oversees the audit and selects the independent accountant. In prior years the Finance Committee held this responsibility.”
The 2025 Form 990 instructions describe the Single Audit trigger as $750,000 of federal expenditures, while the current eCFR text of 2 CFR 200.501 (up to date as of October 7, 2026) states $1,000,000. Confirm with your auditor which applies to your fiscal year. Our SEFA guide covers the records behind that audit.
Audited statement reconciliations go on Schedule D, not Schedule O
The revenue and expense reconciliations to audited financial statements are Schedule D Parts XI and XII, required when you answered “Yes” on Form 990 Part IV line 12a. The explanations for their “other” lines (2d and 4b) go in Schedule D Part XIII.
Who is exempt
Schedule O belongs to Form 990 and Form 990-EZ only. A 990-EZ filer needs it only when a 990-EZ answer calls for an explanation, such as other revenue on line 8. Organizations that submit the Form 990-N e-Postcard instead do not file it.
Deadlines and penalties
Schedule O is due with Form 990. The IRS treats a missing required explanation as an incomplete return, and the 2025 instructions state the penalty under section 6652(c)(1)(A) as $25 per day, up to the lesser of $13,000 or 5% of gross receipts. For organizations with gross receipts over $1,309,500, the penalty is $130 per day, up to $65,000.
If you amend a return, use Schedule O to list each part, schedule and line that changed and describe the amendments.
Records you must keep
The Form 990 instructions say books and records must be kept as long as their contents may become material to the administration of any internal revenue law. Your Form 990, including Schedule O, must be made available for public inspection for three years from its due date (including extensions) or filing date, whichever is later.
For each narrative, keep the record listed in the table above. Part VI Section B counts a policy only if the board or an authorized committee adopted it by year end, so keep the dated resolution. For line 11a, the IRS accepts an emailed link to a password-protected site holding the full return, so keep that email.
What to set up in your systems
In the accounting system
Keep the Form 990 account mapping in the general ledger, not in the preparer’s workpapers. Give Part XI line 9 items (pledge write-offs, contribution refunds, grant reversals) their own accounts or a reporting dimension, so one report produces the itemized list and total. Do the same for the detail behind Part IX lines 11g and 24e.
Attach the support to the entries themselves. Sage Intacct, for example, documents that you can view or attach supporting documents directly from the journal entry list. See other ledgers in our nonprofit accounting software guide.
In the board portal
Most Part VI evidence belongs in the board portal: a policy library with adoption and review dates, minutes with approval dates, and a dated record of when the final Form 990 was posted for directors. Our article on board management software for nonprofits covers the wider feature set.
For line 12c, the annual disclosure cycle is the main record. OnBoard says its D&O questionnaire tool supports conflict of interest questionnaires, includes integrated e-signatures and lets you export completed questionnaires as PDF or Word. Diligent says its questionnaires pre-fill each person’s answers from the prior year and let you track completion. Neither vendor publishes pricing on those pages.
A Schedule O source table
Keep a one-page table mapping each Schedule O entry to its owner, system, document and date, and update it when the board acts rather than at filing time. The preparer then drafts each narrative from the linked record, and the reviewer checks it against the same record.
How we researched this
We read the current IRS instructions for Schedule O, Form 990 (2025) and Schedule D, and the eCFR text of 2 CFR 200.501, on October 10, 2026. We also reviewed pages that rank for “form 990 schedule o,” including a 2016 SF Magazine article and an e-filing vendor’s page; neither offered sample wording. Product statements come from vendor pages, marked where the source sells the product.
Related guides
- Form 990 Schedule A: The Public Support Test Explained
- Form 990-T: Filing Rules and Pulling UBTI From the Ledger
- Statement of Functional Expenses: Template and How-To
Frequently asked questions
Does every nonprofit that files Form 990 have to file Schedule O?
Yes. The IRS instructions say all organizations that file Form 990 must file Schedule O, and at a minimum it must answer Part VI lines 11b and 19. Form 990-EZ filers need it only when a 990-EZ line calls for an explanation.
What if our board did not review the Form 990?
You still answer line 11b. The instructions tell you to enter “No review was or will be conducted.” Federal tax law does not require a board review, but the answer is public.
Can we copy last year’s Schedule O?
You can start from it, but check each statement against this year’s records. A carried-forward answer that no longer matches your practice is incorrect information on the return.
Where do we explain the reconciliation to our audited financial statements?
Not on Schedule O. The revenue and expense reconciliations are Schedule D Parts XI and XII, and their explanations go in Schedule D Part XIII. Schedule O handles the Form 990 Part XI line 9 itemization and the Part XII questions.
Sources
- IRS, Instructions for Schedule O (Form 990) (12/2024), page last reviewed or updated April 30, 2026. irs.gov
- IRS, Instructions for Form 990 Return of Organization Exempt From Income Tax (2025), Part VI, Part XI, Part XII, due dates and penalties, page last reviewed or updated April 30, 2026. irs.gov
- IRS, Instructions for Schedule D (Form 990), Parts XI through XIII, page last reviewed or updated April 30, 2026. irs.gov
- eCFR, 2 CFR 200.501 Audit requirements, up to date as of October 7, 2026. ecfr.gov
- SF Magazine (IMA), A.P. Curatola, Form 990 and Schedule O, November 2016 issue (no exact date shown). sfmagazine.com
- Tax990, Form 990 Schedule O, updated August 21, 2024. Tax990 sells Form 990 e-filing software. tax990.com
- OnBoard, D&O Questionnaires, no date shown. OnBoard sells the product described. onboardmeetings.com
- Diligent, Directors and Officers Questionnaires, March 24, 2025. Diligent sells the product described. diligent.com
- Sage Intacct Help, Video: Journal entries, manage attachments, last modified October 8, 2026. Sage sells the product described. intacct.com
Sherman Hsieh
Independent analysis of enterprise software — ERP, CRM and more
