CLE How to Responsibly Review the IRS Form 990 in Today’s Political Climate
PBI CLE – This CLE, designed to help build confidence when reviewing the IRS Form 990, is an essential course for attorneys serving as board members, officers, or advisors to nonprofit organizations, particularly in light of anticipated updates to this form coming in 2026.
As a publicly available document reflecting a nonprofit’s governance, finances, program activities, and compliance, the IRS Form 990 is a critical transparency tool relied upon by regulators, donors, watchdog organizations, and the media. Proposed changes to the form – including revised reporting requirements for government contracts, federal grants, and fiscal sponsorship arrangements designed to improve transparency and strengthen tax administration — may significantly affect how nonprofit activities are disclosed and interpreted, increasing the need for careful, informed review.
The session will begin with an overview of the structure and purpose of the current Form 990, including its core sections, schedules, and narrative components. The review will highlight areas that consistently garner attention — such as executive compensation, conflicts of interest, related-party transactions, governance disclosures, related-entity structure, and program service accomplishments — and then address how forthcoming updates may impact completion and outside scrutiny of this form and how nonprofit organizations can best prepare for these changes.
The program will further explore the legal and ethical responsibilities of attorneys involved in the review process, including fiduciary duties, privilege considerations, and advising nonprofit leadership on accurate and complete disclosures. Practical strategies will be provided for coordinating with accountants, development teams, and executive staff to ensure the organization’s return reflects both compliance and best practices in transparency.
By the end of this session, participants will be prepared not only to conduct a responsible review of the current IRS Form 990, but also to proactively adapt to upcoming changes — helping their organizations mitigate risk, maintain public trust, and meet evolving regulatory expectations.

