Exemption Watch · testing

Testing

The IRS revokes tax-exempt status on a schedule. Nobody tells your client.

Three consecutive years without a Form 990, 990-EZ, 990-PF, or 990-N and the exemption is gone by operation of law. The revocation takes effect on the due date of the third missed return, and the IRS posts it on a list that updates monthly.

One organization can watch its own calendar. A firm with 200 nonprofit clients cannot. That is the only reason this page exists.

3 years

of missed returns before revocation is automatic

Source: IRC § 6033(j)

Monthly

cadence of the IRS Auto-Revocation List

Source: IRS, Automatic revocation of exemption

$275 / $600

2026 user fee for Form 1023-EZ / Form 1023 reinstatement

Source: Rev. Proc. 2026-5

Why this fails quietly

The 990-N is easy to forget

Small organizations file an electronic postcard, not a return. It cannot be extended, it carries no late penalty, and it is usually the treasurer's job. When the treasurer changes and nobody says so, three years pass.

The effective date is in the past

Revocation is effective on the due date of the third missed return, which can be months before the name is posted. By the time anyone sees it, donations in the gap were not deductible.

The list never forgets

A reinstated organization stays on the Auto-Revocation List. Only the reinstatement date tells you it is clear. A search that stops at "found on list" produces the wrong answer in both directions.

The four pages worth reading

Each one answers a question that comes up before anyone buys anything.

What a monthly check would return

  • Newly posted revocations among your EINs, with the effective date and posting date.
  • Reinstatements, so a cleared client stops showing as revoked in your own file.
  • Organizations with no posting but a filing gap that is one year away from revocation.
  • EINs that return nothing in the IRS search at all, which is its own problem.

The first version of this is a spreadsheet, not a dashboard. We would rather send you a correct file with the source dates on it than a screen that implies more coverage than we have.

Questions

Who is this for?

Anyone responsible for more than a handful of EINs: a CPA firm with nonprofit clients, a fiscal sponsor, an association whose chapters file their own returns, a community foundation running a grantee portfolio. The product only makes sense when checking by hand stops being possible.

Is this a product today?

No. It is a test. The pages below are reference material, and the first customer runs are manual: send a list of EINs, get back a table within two business days. A dashboard only gets built if someone pays for the manual version first.

How is this different from a filing tool?

Filing tools help one organization file one return. This is the other direction: one list of many organizations, checked against what the IRS published this month, with the changes surfaced. The two are complementary, and we are not building a filing product.

Enrollment Watch is not a law firm or a CPA firm. Nothing here is tax or legal advice, and we do not sign or file anything on your behalf.