Reference
The Auto-Revocation List, read correctly
The IRS publishes one list of organizations whose tax-exempt status was automatically revoked for failing to file a required return or notice for three consecutive years. It updates monthly. It is a historical record, not a current-status lookup, and the difference is where most errors happen.
The list includes the name, EIN, exemption type, last known address, the effective date of revocation, the date the name was posted, and the reinstatement date where one exists. Every field is doing work. Reading two of them is how a compliance file ends up wrong.
Seven fields, and what each one will not tell you
| Field | What it says | What it does not say |
|---|---|---|
| Organization name | The legal name on file with the IRS. | A DBA or a popular name. Search by EIN when you can. |
| EIN | The identifier to match on. Names are not unique. | Whether the EIN belongs to the entity you think it does. Verify against the client file. |
| Exemption type | The subsection the organization was recognized under. | Whether it was eligible to file a 990-N in the missed years. |
| Last known address | Where the IRS sent the CP-120A letter. | A current address, or that anyone received the letter. |
| Effective date of revocation | The due date of the third consecutive missed return. | The date the IRS noticed, or the date the name was published. |
| Posting date | The date the name was added to the public list. | When the organization found out. |
| Reinstatement date | Present when the IRS has since reinstated the organization. | Whether the reinstatement was retroactive to the revocation date. |
Two dates, and only one of them is when anyone noticed
The effective date is the original due date of the third consecutive missed return. The posting date is when the name went public. They can be months apart, and the gap is not administrative trivia: contributions made after the effective date are not deductible, even if nobody knew yet.
The IRS also mails a CP-120A letter to the last known address. Assume it did not arrive. Boards change, mail forwarding expires, and the address on file is often the founder's old office.
On the list, and fine
A reinstated organization stays on the list. The reinstatement date sits on the same row. So "found on the Auto-Revocation List" is not a finding. The finding is: revoked, and no reinstatement date, and the revocation is recent enough to matter. Or: reinstated, but your records still say revoked, which means your own list is now the stale one.
To confirm current status, check Pub. 78 data for a 501(c)(3) eligible to receive deductible contributions, or the determination letter, whose effective date should be on or after the revocation date. The list alone cannot answer it.
The 990-N trap
Small organizations file Form 990-N, an electronic postcard, instead of a full return. It cannot be extended. It carries no late-filing penalty. It takes minutes. Those three facts make it the most skipped filing in the sector, and three skipped years is automatic revocation.
A late 990 or 990-EZ generates a penalty notice that gets someone's attention. A late 990-N generates nothing until the exemption is gone. That is why the failure mode clusters around small organizations with volunteer treasurers and annual leadership turnover.
What to do with a hit
- Confirm the EIN matches the entity you think it does, not just the name.
- Read the reinstatement date before you call anyone.
- Check Pub. 78 or the determination letter for current status.
- If there is no reinstatement, the question is not "why" but "which of the four reinstatement paths applies, and has the 15-month window closed."
The 15-month clock runs from the later of the CP-120A letter date or the posting date. Miss it and the standard changes from a form to a reasonable-cause argument for each missed year.
Questions
Does appearing on the list mean the organization is revoked right now?
No. The list is a historical record. An organization can appear on it and later be reinstated, and the reinstatement date is shown on the same row. Reading the revocation date without reading the reinstatement date is the most common way to get this wrong.
Why is the revocation date earlier than the date it was posted?
The effective date is the original due date of the third consecutive missed return. The posting date is when the IRS added the name to the public list, which comes later. Donations made between those two dates are already affected.
Are churches on this list?
Generally no. Churches, their integrated auxiliaries, and certain church-related organizations are not required to file an annual return or notice, so they are not subject to automatic revocation for non-filing. That exception is also why a missing record for a church is not evidence of a problem.
Can an organization be removed from the list after reinstatement?
The IRS keeps the revocation on the list unless the name was posted in error. Reinstatement adds a date; it does not erase the row. Your own records need to hold both facts, or you will keep flagging a client who is already clear.
Next: the four reinstatement paths or the 990 deadline calculator.