Tax Insight

Few changes to 2025 Form 990 with supporting organization regulations reflected in Schedule A

Insight
5 minute read
August 27, 2026

What happened?

The 2025 Form 990, Return of Organization Exempt from Income Tax, contains relatively few substantive changes from the 2024 version, apart from minor stylistic revisions and updated references to IRS guidance.

One notable change appears in the Schedule A instructions, which have been modified to reflect final Treasury regulations that were issued in October 2023 addressing Type I and Type III supporting organizations. The 2025 instructions clarify the annual notification and responsiveness requirements owed to each supported organization, implement the final rules for functionally integrated organizations that support governmental entities, and revise the parent-of-supported-organizations test. For non-functionally integrated Type III organizations, the instructions also refine which expenditures qualify as distributions, including the limited treatment of fundraising expenses.

PwC is pleased to make available our annotated versions of the 2025 Form 990, accompanying schedules, and instructions. The documents include PwC’s highlights and comments on key changes for 2025, and they are fully searchable and bookmarked for ease of navigation.

Actions to consider

Failure to timely file a complete and accurate Form 990 can result in adverse consequences, including penalties and, in certain cases, loss of tax-exempt status. Organizations should take steps to avoid nonconforming or incomplete responses on Form 990 that could invite additional IRS scrutiny.