How to File Form 990 for Previous Tax Years

When filing Form 990 for a previous tax year, the first step is to identify the specific tax year for which you need to submit the return.

Under the Taxpayer First Act of 2019 and IRC Section 6033(n), electronic filing is generally required for applicable Form 990 series returns.

However, the IRS accepts electronically filed exempt organization returns only for the current tax year and two prior tax periods. Returns outside the supported electronic filing window must generally be submitted on paper.

1. Electronic Filing for Current and Previous Tax Years

For example, during the 2025 Form 990 filing cycle in 2026, the following tax years fall within the three-year electronic filing window:

Important: These examples relate to the 2025 return filing cycle. The available tax years change as the IRS advances to a new filing cycle. Fiscal-year returns may also require checking the applicable tax period and IRS system availability.

2. Paper Filing for Older Tax Years

If you need to file Form 990 for an older tax year that is no longer supported by the IRS electronic filing system, you may use the paper filing method.

For example, if you are filing a 2022 Form 990 in the 2025 filing cycle, electronic filing is no longer available for that tax year. Therefore, you should use the 2022 version of Form 990 and submit it to the IRS by mail.

The IRS instructs organizations to write the following statement at the top of page 1 when filing an older return on paper:

"The IRS no longer accepts e-file of the 2022 Tax return"

This statement explains why the return is being filed on paper despite the general electronic filing requirement.

Check IRS Electronic filing for Nonprofit page regarding the mandatory e-filing for Form 990

The filing method is only one part of the process. Before submitting a previous-year return, you should also review whether the organization missed one year or multiple consecutive years.

Let's understand the IRS requirements through two common scenarios/examples.

Scenario 1 - I Missed Filing Form 990 for 2022 Only

Suppose your organization successfully filed Form 990 for tax years 2023, 2024, and 2025, but missed filing for 2022.

Since the organization did not miss three consecutive years, this single missed filing does not, by itself, trigger automatic revocation of its tax-exempt status under IRC Section 6033(j).

You can generally submit the missing 2022 return using the paper filing method because that tax year is outside the supported electronic filing window.

How to File the Missing 2022 Form 990?

Step 1: Download the Correct Tax Year Form 990

Visit the IRS website and download the Form 990 applicable to tax year 2022.

Do not use the latest Form 990 version to report financial information for 2022. Each return must be prepared using the form, schedules, and instructions applicable to the tax year being reported.

Download the prior year tax forms here

Step 2: Explain Why You Are Filing on Paper

As required by the IRS instructions, enter the following statement at the top of page 1 of the return:

"The IRS no longer accepts e-file of the 2022 Tax return."

This identifies the reason for submitting the older return on paper.

Step 3: Complete the Required Financial Information

Prepare Form 990 using your organization's financial records for the 2022 tax year.

Make sure to include:

• Organization name and Employer Identification Number (EIN).

• Gross receipts, revenue, and expenses.

• Assets, liabilities, and net assets.

• Program service accomplishments.

• Governance and compensation information.

• All required schedules and supporting statements.

Complete the return according to the 2022 Form 990 instructions and ensure it is properly signed by an authorized officer.

Step 4: Review Late-Filing Penalties and Reasonable-Cause Relief

Under IRC Section 6652(c)(1)(A), the IRS may assess penalties when an organization fails to file its required annual information return by the due date, including any applicable extension.

The penalty amount depends on the return's original filing due date and the organization's gross receipts. Because the penalty amounts are adjusted for inflation, you should review the applicable tax year's IRS instructions rather than use the current year's penalty rate for an older return.

Check IRS Late filing procedure for exempt organization Page to predict the penalty amount

If the organization has a reasonable explanation for missing the deadline, it should provide a reasonable-cause statement explaining why the return was filed late.

Step 5: Mail the Completed Form 990 to the IRS

Once the return is completed, mail the signed Form 990, all required schedules, and any applicable explanation to the appropriate IRS mailing address.

Check the current IRS mailing instructions before sending your return, as addresses may vary depending on the form and delivery method.

Keep a copy of the completed filing and proof of mailing for your organization's records.

Scenario 2 - I Missed Filing Form 990 for 2022, 2023, and 2024

Next is the scenario when your organization has not submitted its mandatory annual filings for three consecutive tax years: 2022, 2023, and 2024.

This scenario demands extra attention due to the automatic revocation provisions of the IRS. According to IRC Section 6033(j), an organization which fails to submit a Form 990 series or Form 990-N for three consecutive years automatically loses its tax exemption status.

In the case of an organization which failed to file returns for 2022, 2023, and 2024, automatic revocation would be effective from the due date for filing the third return in 2025.

If the organization's tax-exempt status has been automatically revoked, it must apply for reinstatement to regain that status. IRS offers various procedures for reinstatement of tax exempt status according to Revenue Procedure 2014-11.

Condition 1: Small Organizations Applying Within 15 Months

Streamlined Retroactive Reinstatement — Revenue Procedure 2014-11, Section 4

Small organizations may qualify for a simplified reinstatement process if they:

• Were eligible to file Form 990-EZ or Form 990-N for all three missed years.

• Have never had their tax-exempt status automatically revoked before.

• Apply within 15 months of the later of the IRS revocation letter date or the date they appeared on the IRS Auto-Revocation List.

How to Apply?

Submit Form 1023 or Form 1023-EZ (if eligible), or another applicable exemption application, with the required user fee.

• Form 990-EZ: Submit the missing paper returns marked "Retroactive Reinstatement" to qualify for applicable penalty relief.

• Form 990-N: Prior-year filings are not required for penalty relief under this procedure.

If approved, the IRS can restore the organization's tax-exempt status from the original revocation date.

Condition 2: Organizations Not Eligible for Streamlined Reinstatement

Retroactive Reinstatement — Revenue Procedure 2014-11, Sections 5 and 6

Organizations that were required to file Form 990 or Form 990-PF, or have previously had their tax-exempt status revoked, may qualify for retroactive reinstatement through a different process.

The requirements depend on when they apply:

How to Apply?

File the applicable exemption application, such as Form 1023, with the required user fee. Submit the missing Form 990 returns marked "Retroactive Reinstatement" according to IRSinstructions.

If the IRS approves the request, tax-exempt status may be restored from the original revocation date.

Refer IRS page on Requesting retroactive reinstatement to know detailed steps

Key Points to remember before filing previous year’s Form 990

Conclusion

The preparation and filing of Form 990 for earlier years entails the need to understand IRS electronic filing restrictions, the requirements for filing returns late, and whether your entity is exempt from taxes. 

Regardless of the number of years that your entity may have failed to file Form 990, it is necessary to identify the right way to file and the procedures applicable. In case your entity has the capability to e-file forms, then e-File990, which is an IRS authorized portal, offers an online platform to prepare and electronically submit supported Form 990 series returns. 

File your Form 990 Online with e-File990 Now!