Automatic revocation is the most serious consequence of not filing, and the most avoidable. It doesn't depend on how much money the organization has or whether it owes anything. The IRS doesn't need to send a warning first, and there is no appeal.
The rule
Under Internal Revenue Code section 6033(j), an organization that fails to file a required annual return (Form 990, 990-EZ, 990-PF or 990-N) for three consecutive years automatically loses its tax-exempt status.
The revocation is effective on the original due date of the third missed return. If the organization had filed an extension for that third return, the revocation still dates back to the original due date once the extended date passes without a return.
Small organizations are hit hardest. A group with gross receipts normally $50,000 or less owes no penalty for a late Form 990-N, so nothing gets its attention until the exemption is gone.
A calendar-year neighborhood association that stopped filing. It didn't file for 2022, 2023 or 2024.
| Tax year | Original due date | Status |
|---|---|---|
| 2022 | Monday, May 15, 2023 | Missed (year 1) |
| 2023 | Wednesday, May 15, 2024 | Missed (year 2) |
| 2024 | Thursday, May 15, 2025 | Missed (year 3) |
Its exemption is revoked effective May 15, 2025. Suppose its name then appears on the IRS revocation list on October 14, 2025, after a CP-120A letter dated earlier. The 15-month window runs from the later of the two dates, so it closes on January 14, 2027. If the association applies by then, and it was eligible for the 990-EZ or 990-N in all three years, it can use the streamlined route below. Had it filed any one of those three returns, even late, before the third due date passed, the run would have been broken.
What revocation means
- The organization is no longer tax-exempt and may have to file Form 1120 (corporations, due the 15th day of the 3rd month after year end) or Form 1041 (trusts, due the 15th day of the 4th month) and pay income tax.
- Contributions are no longer tax-deductible and the organization is removed from Publication 78, the IRS's list of organizations eligible to receive deductible gifts. Gifts made before the organization appears on the revocation list remain deductible.
- Grantmakers that check status often stop funding immediately.
- State tax exemptions and state charity registrations tied to federal status can be affected.
- A proper automatic revocation can't be appealed.
Where revocations are published
The IRS publishes revoked organizations on the Auto-Revocation List in its Tax Exempt Organization Search tool, updated monthly. The list shows the name, EIN, last known address, effective date of revocation and the date the organization was added. The IRS also mails a CP-120A notice; see IRS notices for nonprofits for how to read it. Anyone, including donors and foundations, can search the list.
The four ways back (Rev. Proc. 2014-11)
Every route starts with a new application for exemption (Form 1023, 1023-EZ, 1024 or 1024-A, depending on the type of organization) and the user fee. The IRS lists the current fees as $600 for Form 1023 and $275 for Form 1023-EZ, paid through Pay.gov when the application is filed. What differs is how far back the reinstatement reaches and what you must show.
| Route | Who can use it | Deadline | What it requires | Reinstated back to |
|---|---|---|---|---|
| Streamlined retroactive (section 4) | Organizations eligible to file the 990-EZ or 990-N for each of the three missed years, and never auto-revoked before | Within 15 months of the later of the CP-120A letter or the date the organization appeared on the revocation list | Application and fee; no reasonable-cause statement | The date of revocation |
| Retroactive within 15 months (section 5) | Everyone else, including organizations that had to file the full 990 or 990-PF | Within 15 months, as above | Reasonable cause for at least one of the three years, plus paper returns for the missed years | The date of revocation |
| Retroactive after 15 months (section 6) | Any organization | Any time after 15 months | Reasonable cause for all three years, plus paper returns for the missed years | The date of revocation |
| From the application date (section 7) | Any organization | Any time | Application and fee | The postmark date of the application |
Form 1023-EZ can be used for the streamlined and application-date routes if the organization is otherwise eligible for it; it can't be used for the section 5 or 6 routes.
What a reasonable-cause statement needs
A reasonable-cause statement shows the organization used ordinary business care and prudence in trying to meet its filing requirement. The IRS asks for a detailed description of all the facts: why the organization failed to file, how it discovered the failure, and the steps it has taken or will take to prevent it happening again.
Avoiding penalties for the missed years
An organization using the streamlined route that wants to avoid late-filing penalties for the missed years can file paper Forms 990-EZ for those years, marked "Retroactive Reinstatement" as the procedure directs. Years in which it was eligible for the 990-N don't need back filings. Under the section 5 and 6 routes, the IRS won't impose the penalty for the three years if the organization is reinstated retroactively and files the required paper returns.
Applying for reinstatement, step by step
- Confirm the revocation and note the effective date and the date the organization was added to the list.
- Calculate your 15-month deadline from the later of the CP-120A date and the listing date.
- Work out which return each missed year required (see which Form 990 to file). That decides whether the streamlined route is available.
- Prepare the missed returns, on paper, marked "Retroactive Reinstatement," if your route requires them.
- Draft the reasonable-cause statement if your route needs one.
- File the application with the user fee, checking the box for the right section of Rev. Proc. 2014-11.
- Keep filing every year while the application is pending.
Why the 15-month window matters
The two most forgiving routes, retroactive reinstatement with little or no reasonable-cause showing, are only available if the application is filed within 15 months. After that, retroactive reinstatement requires showing reasonable cause for every missed year, which is a much harder case. If you have received a CP-120A or found your organization on the list, act now.
Preventing it
The fix is simple: file something every year. Even an organization with no money files a 990-N. Keep the due date on more than one person's calendar, and keep login access with the organization. If you've already missed one or two years, filing now breaks the run. See catching up on late returns.
Frequently asked questions
How do we find out if we were revoked?
The IRS mails a CP-120A letter, and revoked organizations appear on the Auto-Revocation List in the IRS Tax Exempt Organization Search, updated monthly. Search your EIN there.
Can we just start filing again?
No. Once revoked, filing a 990 doesn't restore exemption. You must apply for reinstatement, even if the organization was never required to apply for exemption in the first place. Until it is granted, the organization is treated as taxable.
Are gifts our donors already made at risk?
Contributions made before the organization appears on the revocation list remain deductible. Gifts after that date are not deductible unless exemption is reinstated retroactively.
Will we come off the revocation list after reinstatement?
A reinstated organization stays on the Auto-Revocation List, which shows the date of reinstatement. The IRS also adds it back to Tax Exempt Organization Search. Keep the new determination letter to show donors and grantmakers.
We think we were revoked by mistake. What now?
If you did file, gather proof: IRS acceptance acknowledgments, e-Postcard confirmations or certified-mail receipts. The IRS has a process for organizations that believe they were revoked in error, described on its automatic revocation pages.
Sources
- IRS: Automatic revocation of exemption. irs.gov
- IRS: Automatic revocation, how to have your tax-exempt status reinstated. irs.gov
- IRS: Reinstatement of tax-exempt status after automatic revocation. irs.gov
- IRS: Rev. Proc. 2014-11. irs.gov
- IRS: Form 1023 and 1023-EZ, amount of user fee. irs.gov
- IRS: Instructions for Form 8868 (Rev. January 2026). irs.gov
IRS figures change; inflation-adjusted amounts are updated each year. We review this page when the IRS publishes new instructions.
990IRS.com is a private company, not the IRS. This page is general information, not legal or tax advice for your organization. Example organizations and figures are hypothetical.
