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What documents should your organization be keeping?

A nonprofit entity is required to maintain proper records to ensure the organization complies with tax rules and regulations. If an organization is unable to provide supporting documentation proving qualification for tax-exempt status, it is possible the organization will be subject to penalties or revocation of its tax-exempt status under Section 6033(j) of the Internal Revenue Code (IRC). To ensure your nonprofit has adequate documentation, a best practice is to adopt a document retention policy that outlines what records must be retained and for how long.

There is no document retention guideline that covers all nonprofits. Each organization should tailor its document retention policy to the specific state law requirements in which it operates (statute of limitations vary from state to state) and determine what records are relevant to its activities.

The following are common recommendations from the National Council of Nonprofits and the American Institute of Certified Public Accountants relating to the length of time certain records should be maintained. Please note that this is not an all-inclusive list and is given only as a starting point for guidelines.

Document

Retention Period

Articles of incorporationPermanent
BylawsPermanent
Board meeting minutesPermanent
Board policies and resolutionsPermanent
IRS determination letterPermanent
IRS Form 990 tax returnsPermanent
IRS Form 1023, application for tax-exempt statusPermanent
Annual audits and year-end financial statements Permanent
Depreciation schedulesPermanent
Real estate deeds, mortgages, and bills of salePermanent
Retirement and pension plan documentsPermanent
Insurance policiesPermanent
Contracts and leases 7 years after termination
General ledgers7 years
Invoices and expense records7 years
Bank statements and reconciliations3 to 7 years
Payroll records and summaries7 years

 

Categories that are state-specific include laws relating to employment, payroll, and state tax-exempt certifications, which can frequently have varying implications for document retention requirements.

In preparation for a potential Internal Revenue Service (IRS) audit, if you are uncertain as to what documentation supporting your nonprofit’s returns should be retained and the length of that retainage, please contact your local Blue & Co. representative for guidance.

When the retention period of any particular document has ended, be sure to consider if there is a need for non-tax purposes, such as for grants, insurance purposes, creditor requirements, or state agency obligations that may require the nonprofit to retain records longer than IRS requirements.  Furthermore, consider if there are specific documents that should be retained which may hold historical value or valuable institutional memories that are specific to the organization. If the organization does determine a document can be disposed of, be sure to erase, shred, or destroy the document to ensure any confidential information cannot be reconstructed.

Additional Resource:
Compliance Guide for 501(c)(3) Public Charities

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