For tax‑exempt organizations, IRS Form 990 serves as a critical public disclosure document that communicates financial activity, governance practices, and organizational accountability. Because of its visibility and legal significance, understanding who is authorized to sign the form is essential to maintaining strong compliance and public trust.
Although IRS Form 990, Return of Organization Exempt from Income Tax, is often viewed as a routine compliance filing rather than a traditional tax return, it carries significant governance and legal implications. The form should be reviewed by the organization’s full Board of Directors and must be signed by the organization’s principal officer.
A principal officer is defined as the individual who, regardless of title, has ultimate responsibility for implementing decisions of the governing body or for overseeing the management, administration, or operations of the organization. This role is typically filled by an authorized corporate officer such as the president, vice president, treasurer, assistant treasurer, chief accounting officer, or tax officer.
The signing officer attests under penalty of perjury that the information reported on Form 990 is accurate and complete. Because of this, the individual signing must have a thorough understanding of the organization’s financial activities and must be actively serving in their officer role at the time the form is filed.
While paid preparers may complete Form 990, they cannot sign on behalf of the organization unless they have been granted a formal Power of Attorney. Likewise, an Executive Director may sign only if they have been officially designated as an authorized officer.
In summary, selecting the appropriate signing officer is a critical governance decision. The designated officer must understand the complexities of Form 990 and recognize that their signature carries legal responsibility for the organization’s compliance, transparency, and public financial reporting—factors that directly influence public trust.
Please contact the Not-for-Profit Niche team at Gilliam Bell Moser LLP for further guidance.
