Filing a Late Form 990-EZ: Penalties, Reasonable Cause and How to Catch Up

Many small groups start out filing the Form 990-N e-Postcard. Then a good fundraising year pushes gross receipts past the 990-N limit, the group has to file Form 990-EZ instead, and nobody notices until the due date has passed.

The difference matters. The IRS charges no penalty for a late 990-N. A late 990-EZ is different: the IRS can charge a penalty for every day it is late. This guide explains what that penalty is, how to ask for relief, and what to file first.

What the IRS charges for a late 990-EZ

The Form 990-EZ instructions (General Instruction G) set the penalty against the organization. In the 2025 instructions it is $25 a day, up to the lesser of $13,000 or 5% of the organization's gross receipts for the year.

Here is how the cap works, using made-up numbers. A booster club with $120,000 of gross receipts files its 990-EZ 300 days late. Five percent of $120,000 is $6,000, which is less than $13,000, so the most the IRS can charge is $6,000. At $25 a day, that cap is reached after 240 days.

A few more points from the instructions:

• The amounts change. The IRS's own penalty page gives lower figures for returns due in 2021 and 2022. Use the instructions for the year you are filing.
• An incomplete return counts too. The penalty applies to a return filed without the required information. For example, a 990-EZ that neither checks the Item H box nor attaches Schedule B is treated as incomplete.
• Paper doesn't count. The instructions say an organization that must file electronically but files on paper is treated as not having filed at all.
• People can be charged as well. If the IRS sends a letter giving a fixed time to file, and the return still isn't filed, the person responsible can be charged $10 a day, up to $6,500 per return (2025 figures).

The due date itself has not changed: the 15th day of the 5th month after your year ends, or the next business day if that falls on a weekend or holiday. Use the due date calculator to check any year.

It's too late for an extension

Form 8868 gives an automatic six-month extension, but only if it is filed by the original due date. The Form 8868 instructions say an 8868 filed after the original due date does not extend it. Once the date has passed, the only fix is to file the return. See what Form 8868 does.

Asking for relief: reasonable cause

The penalty doesn't apply if the organization can show the late filing was due to reasonable cause. Each case is judged on its facts. On its reasonable cause page, the IRS gives examples such as:

• fires, natural disasters or civil disturbances;
• not being able to get your records;
• death, serious illness or unavoidable absence;
• system problems that delayed a timely e-filing.

The 990-EZ instructions say a late return should include a statement giving the reasons it was not filed on time. In 990.tax you can add that statement to your return. When a 990-EZ is past its due date, the signing step asks you to explain why the return is late. It is optional: a few sentences on what kept the organization from filing on time, such as an officer's illness or records held by a former treasurer. 990.tax sends it to the IRS with the return, and your print copy shows it on its own page. Write it while you still remember: who had the records, when the officers changed, what delayed the filing.

The statement does not cancel a penalty on its own. The IRS still decides whether there was reasonable cause. If you later receive an IRS penalty notice, the IRS says you can ask for relief by calling the number on the notice or in writing on Form 843. Keep your notes for that.

Don't plan on "first-time abatement." The IRS page for that relief lists penalties on other kinds of returns and does not list this one.

990.tax cannot advise on penalty relief. For a large notice, talk to a tax professional.

Tax year 2023 can be e-filed only until late December

The 990-EZ instructions say electronic filing is only available for the current tax year and the two before it. The window moves forward once a year, at the IRS's late-December changeover. After the changeover in December 2026, tax year 2023 drops out, and the instructions say a year outside the window has to be filed on paper.

Your tax year is the year your accounting year begins. A school-year group with a July 2023 to June 2024 year is filing tax year 2023, so it is in the same position. See fiscal year and tax year.

If you owe a 2023 990-EZ, file it now. Every day adds to the penalty, and from January it can no longer be e-filed.

Watch the three-year count

Penalties are not the only risk. The IRS revokes the exemption of any organization that does not file a required Form 990, 990-EZ or 990-N for three consecutive years. A group that switched from the 990-N to the 990-EZ is still counting the same years.

Check your EIN with our revocation lookup before you file. If you were already revoked, filing the missing returns does not undo it; see how revocation and reinstatement work and missed years and automatic revocation.

California groups: Form 199 is late too

If your group is in California, the FTB Form 199 for the same year is probably late as well. The FTB booklet says:

• Form 199 is due the 15th day of the 5th month after your year ends, with an automatic six-month extension, unless the organization was not in good standing or was suspended on the original due date.

• A late return is charged $5 for each month or part of a month, up to $40.

• The FTB can waive the penalty for reasonable cause.

• Not filing can lead to suspension or revocation of the exemption in California.

  990.tax files Form 199 together with your 990-EZ; see Form 199 with 990.tax.

A catch-up checklist

1. Check your status with the revocation lookup.
2. List the missing years and the form each one needs. Gross receipts decide it; see which form do I file?
3. Start with tax year 2023 if it is missing, before the December changeover.
4. Write down the reasons for the delay. Add them to the return as your reasonable cause statement, and keep them in case a penalty notice arrives.
5. Put the next due date where the next treasurer will see it.

File your late 990-EZ with 990.tax

990.tax e-files Form 990-EZ, including Schedules A and O, and California Form 199 with it. As of November 2026 it files tax years 2023 and 2024. You answer plain-language questions, add a reasonable cause statement if the return is late, an officer signs online, and the IRS acknowledgement appears in your account. There is one price per filing and no subscription (pricing).

If your return needs a schedule we don't file yet, such as Schedule B, the app tells you before you pay. Read the Form 990-EZ filing guide or the step-by-step help article first if you want to see what it asks.

Start your 990-EZ on 990.tax

990.tax is an IRS-authorized e-file provider. It is not affiliated with the IRS or the FTB.

This post is general information, not legal or tax advice.

Sources

• IRS: Instructions for Form 990-EZ (2025)
• IRS: Instructions for Form 8868
• IRS: Annual exempt organization return - penalties for failure to file
• IRS: Penalty relief for reasonable cause
• IRS: Penalty relief due to first time abate or other administrative waiver
• IRS: Automatic revocation of exemption
• FTB: 2025 Form 199 booklet