Form 1023 vs 1023-EZ: Which 501(c)(3) Application Applies

Important note: This guide is general planning information, not legal, tax, or accounting advice. Eligibility depends on entity type, purposes, activities, finances, and formation documents that only your organization has. Verify current requirements with the IRS and qualified help before relying on them. User fees and IRS processing figures below carry the date they were checked; both change.

On this page

• Form 1023 vs 1023-EZ is not a choice you make
• The three financial tests for Form 1023-EZ eligibility
• What else takes Form 1023-EZ off the table
• What the full Form 1023 asks for
• Form 1023 and 1023-EZ fees, filing, and processing time
• How to apply, in order
• The 27-month rule and your 501(c)(3) effective date
• What happens while a 501(c)(3) application is pending
• How to check your Form 1023 or 1023-EZ application status
• Organizations that do not have to file Form 1023 at all
• Related NPO Resources guides
• Sources reviewed
• Frequently asked questions

Form 1023 vs 1023-EZ is not a choice you make

Two organizations apply for 501(c)(3) recognition in the same week. One answers “No” to all 34 questions on the IRS eligibility worksheet and files the short form. The other answers “Yes” to one, and files the full application with a narrative of activities, financial data, and its organizing document.

They did not pick different levels of effort. They answered a worksheet differently.

The IRS publishes the rule in two places. Revenue Procedure 2026-5 lists the organizations that “are not eligible to submit Form 1023-EZ and must use Form 1023.” The Instructions for Form 1023-EZ carry the same content as a worksheet you complete yourself:

“If you answer ’Yes’ to any of the worksheet questions, you are not eligible to apply for exemption under section 501(c)(3) using Form 1023-EZ. You must apply on Form 1023.”

Thirty-four questions. One “Yes” is enough.

	Form 1023-EZ	Form 1023
Who may use it	“No” to all 34 worksheet questions	Everyone else
What you submit	Attestations and an NTEE code	Narrative, financial data, organizing document, schedules
Financial data	None	3, 4, or 5 years depending on age
User fee	$275	$600
Processing	80% within 22 days	80% within 191 days
Expedited handling	Not available	Available in certain cases
Earlier effective date after 27 months	Cannot request	Can request (Schedule E)

There is a second difference that matters more than the page count. Form 1023-EZ is a different kind of promise, not a shorter version of the same one. The long form asks you to show your work. The short form asks you to certify that you already checked. The verification does not disappear; it moves to the other side of the determination.

A self-checkout lane works the same way. Scanning your own items is genuinely faster. What makes it faster is that nobody inspects the basket at the register — which is also why whatever checking happens, happens after.

The three financial tests for Form 1023-EZ eligibility

These are the first three worksheet questions. In the affirmative phrasing of Revenue Procedure 2026-5, an organization is eligible only if all three hold:

• Projected gross receipts of $50,000 or less in the current tax year and the next two
• Past gross receipts of $50,000 or less in each of the last three years it existed
• Total assets with a fair market value not exceeding $250,000

Two details are easy to miss. The projection is forward-looking, so an organization planning a capital campaign or a first large grant can be under the line today and ineligible on the strength of its own budget. And gross receipts means everything received before subtracting anything — the worksheet defines it as “the total amounts the organization received from all sources during its annual accounting period, without subtracting any costs or expenses.”

The asset test is a fair-market-value test across a full list: cash, receivables, inventory, securities, land, buildings, and equipment. Real property and equipment count toward the $250,000, not just cash.

A number that does not belong here. The figure $5,000 appears constantly in guidance about 501(c)(3) applications. It is not a Form 1023-EZ threshold. It belongs to a different rule — which organizations need not apply at all — covered below.

What else takes Form 1023-EZ off the table

The remaining worksheet questions are categorical rather than financial. An organization is routed to the full Form 1023 if it is or does any of the following, among others:

• Formed outside the United States, or with a foreign mailing address
• Organized as anything other than a corporation, unincorporated association, or trust — an LLC answers “Yes” here
• A church, or a convention or association of churches
• A school, college, or university
• A hospital, medical research organization, or agricultural research organization
• Requesting classification as a supporting organization under section 509(a)(3), or as a private operating foundation
• Maintaining or intending to maintain a donor advised fund
• Investing 5% or more of total assets in securities or funds that are not publicly traded
• Selling or intending to sell carbon credits or carbon offsets

Four questions are newer than most published guidance. The January 2025 revision states that “Question 29 was modified, and questions 31 through 34 were added.” Those four cover a previous denial of recognition, a previous determination that the organization was ineligible to file Form 1023-EZ, activities involving controlled substances prohibited by federal law regardless of state legality, and organizations “engaged in exchanging, creating, or distributing digital assets.” Guidance written before 2025 describes a shorter worksheet and omits all four.

There are also two things the short form simply cannot do. It cannot be used to request an earlier effective date once an organization has existed more than 27 months, and it cannot be used to request an exception from the Form 990-series filing requirement. Either need routes you to Form 1023.

What the full Form 1023 asks for

The long form is longer because it collects evidence rather than assurances.

A narrative of activities. The instructions ask you to “describe completely and in detail your past, present, and planned activities” and warn against repeating the purposes already stated in the organizing document.

Financial data — in Part VI, not Part IX. Anything describing Part IX is copying a pre-2020 paper form. The number of years depends on the organization’s age:

• Less than 1 year old — three years of projections
• More than 1 but fewer than 5 years — four years, actual plus projections
• 5 years or more — the five most recently completed tax years

The IRS adds that it “may request financial information for more than 5 years.”

The organizing document — with two specific clauses. The purpose clause must limit purposes to those in section 501(c)(3), and the dissolution clause must permanently dedicate assets to a 501(c)(3) purpose. Both must be in the organizing document itself. Publication 557 is unusually blunt:

“The requirement that your organization’s purposes and powers must be limited by the articles of organization isn’t satisfied if the limit is contained only in the bylaws or other rules or regulations.”

Bylaws, only if adopted. This is a common misstatement. The instructions say to upload the organizing document “along with a copy of your bylaws, if adopted,” and add that “the other listed documents are not required.” Bylaws are not a precondition for applying.

Schedules A through H, where they apply — for churches, schools, hospitals, supporting organizations, late filers and reinstatement cases, low-income housing, successor organizations, and organizations making grants to individuals.

Form 1023 and 1023-EZ fees, filing, and processing time

Both applications are filed electronically through Pay.gov. Paper is not an option for Form 1023-EZ, where the IRS states it “will not accept printed copy submissions of the application.” A paper Form 1023, 1023-EZ, 1024, 1024-A, or 8940 is returned with the fee.

On the “Form 1023-EZ PDF” question. There is a PDF — but it is not a filing route. The instructions are published as a PDF, and so is an image of the form, which carries the line “Form 1023-EZ is filed electronically only on Pay.gov.” Downloading, printing, and mailing it does not start an application.

As checked on 2026-08-31, the user fees are $275 for Form 1023-EZ and $600 for Form 1023, set in Appendix A of Revenue Procedure 2026-5, effective December 29, 2025. The IRS notes these “are subject to change,” and the schedule sits in a revenue procedure that gets superseded — confirm before paying.

Processing is where published guidance goes stale fastest. The IRS does not publish a fixed range like “three to six months.” What it publishes on the application status page is a rolling submission cutoff per form plus an 80th-percentile figure. As of that page’s June 2026 update, 80% of Form 1023-EZ determinations issued within 22 days, and 80% of Form 1023 determinations within 191 days.

Read those as percentiles, not promises. And note one asymmetry: Form 1023-EZ cannot be expedited. Some other applications can be.

How to apply, in order

The sequence matters, because two steps have to happen before the application exists.

The 27-month rule and your 501(c)(3) effective date

Exemption can be recognized back to the day the organization was legally formed — but only inside a window.

File within 27 months from the end of the month in which the organization was formed, and if the application is approved, exempt status is effective as of the formation date. File later, and it runs from the submission date instead.

The IRS uses two phrasings for this, sometimes in adjacent sentences of the same document — “27 months of formation” and “27 months from the end of the month in which it was organized.” The operative rule is the stricter one. If the date is close, count from the end of the formation month.

It works like a registration window on a warranty. Register inside it and coverage runs from the purchase date. Register after and coverage starts when you filled in the card — the earlier months are simply not covered.

Retroactive recognition is also conditional: purposes and activities during the interim must have been consistent with the requirements for exempt status. Publication 557 adds a consequence most guidance omits — an organization recognized retroactively “can file a claim for a refund of income taxes paid for the period for which its exempt status is recognized.”

Past 27 months, the long form’s Schedule E is the mechanism for asking anyway.

What happens while a 501(c)(3) application is pending

This is the most misreported part of the process, so it is worth stating precisely.

The organization can operate and treat itself as exempt. It does not have to wait for the letter.

Contributors do not have advance assurance that their gifts are deductible. The IRS is explicit:

“However, contributors to the organization do not have advance assurance of deductibility because the organization’s exemption is pending. If the organization ultimately qualifies for exemption for the period in which the contribution is made, the contribution will be tax-deductible by the donor. Alternatively, if the organization ultimately does not qualify for exemption, then the contribution will not be tax deductible.”

Deductibility is retroactive-if-approved, not deductible-now. Any guidance saying donations are deductible while an application is pending has skipped the condition.

The annual filing obligation has already started. The IRS states that a return is required if it comes due “before the organization has submitted its application or while the organization’s application for recognition of exempt status is pending.” The return is filed with the exempt-status-pending box checked on page 1, and it is publicly disclosable like any other.

The meter is already running. So is a second clock: three consecutive years without a required filing revokes exempt status automatically, and that rule does not pause for a pending application. What applies and when it is due is covered in Form 990 Filing Requirements for Nonprofits.

A determination is not permanently settled either. Revenue Procedure 2026-5 provides that the IRS “will select a statistically valid random sample of Form 1023-EZ applications for pre-determination reviews.” The same procedure lists an “incorrect representation or attestation as to … the organization’s eligibility to file Form 1023-EZ” among the grounds on which a determination letter can be revoked or modified retroactively.

How to check your Form 1023 or 1023-EZ application status

The IRS publishes a rolling cutoff rather than a case lookup. On the application status page, each form carries a submission date the reviewers have reached. If you submitted after that date, the application has not been assigned yet and the IRS asks you not to call.

Once a determination issues, it appears in Tax Exempt Organization Search — often before the letter arrives by mail. Checking there is faster than waiting for the envelope.

If you submitted before the posted cutoff and no approval shows in that database, the IRS accepts inquiries by phone or fax from an officer or director authorized to represent the organization. It does not accept email.

Organizations that do not have to file Form 1023 at all

Churches, their integrated auxiliaries, conventions or associations of churches, and organizations other than private foundations whose gross receipts are normally not more than $5,000 per year are not required to file Form 1023 to be recognized under 501(c)(3).

For churches this goes further. They are “automatically considered tax exempt”, donors may deduct contributions even where a church has never sought recognition, and because churches are not required to file an annual return they are not subject to automatic revocation.

Many apply regardless. The IRS gives the reason plainly: recognition “assures contributors that contributions are deductible.”

Note the trap. A church is barred from Form 1023-EZ by the worksheet, and simultaneously exempt from having to apply at all. Those two facts are frequently blended into a single wrong sentence.

If the organization is not seeking 501(c)(3) status, Form 1024 covers most other 501(c) subsections and 501(d), and Form 1024-A covers 501(c)(4) social welfare organizations. A 501(c)(4) also files Form 8976, a separate notice of intent to operate.

Related NPO Resources guides

• Form 990 Filing Requirements for Nonprofits — the annual obligation that begins as soon as an organization claims exempt status, and the three-year rule that ends it.
• Nonprofit Compliance Calendar Checklist — how to record an obligation, assign an owner, and verify each date against an official source.
• Charitable Solicitation Registration: What Triggers It — the state obligation a determination letter does not answer, and what starts it in six states.
• Compliance Resource Finder — state and federal compliance references collected in one place.
• Nonprofit Conflict of Interest Policy: What Form 990 Asks — the conflict of interest policy the IRS encourages at the application stage, and what the annual return asks about it afterward.

Need help with nonprofit accounting and reporting?

Sources reviewed

Information reviewed on 2026-08-31 against the IRS pages linked in this guide. Every figure was confirmed on the IRS page it links to. User fees, processing figures, and worksheet questions change; verify current requirements before applying.

• Instructions for Form 1023-EZ (Rev. January 2025) — eligibility worksheet, attestation, EIN, filing method
• Instructions for Form 1023 (Rev. December 2024) — narrative, financial data, organizing document, schedules, 27-month rule
• About Form 1023 and About Form 1023-EZ
• Revenue Procedure 2026-5, Internal Revenue Bulletin 2026-1 — ineligibility list, user fee schedule, effective dates, pre-determination review, revocation grounds
• Form 1023 and 1023-EZ: amount of user fee
• Where’s my application for tax-exempt status
• Publication 557 (Rev. January 2025) — organizational test, retroactive recognition
• Organizations not required to file Form 1023
• Churches, integrated auxiliaries, and conventions or associations of churches
• Contributions to organization with IRS application pending
• Tax law compliance before exempt status is recognized
• Applying for tax-exempt status and rejecting incomplete applications
• Search for tax-exempt organizations
• About Form 1024 and About Form 1024-A

Frequently asked questions