Written in partnership with Kimberly Hestermann, Fall 2025 Hearst Fellow

This fall, leading members of the U.S. nonprofit community – brought together by the Aspen Institute’s Nonprofit Open Data Collective – submitted comments to the Internal Revenue Service (IRS) on the Form 990 series. The comments focus on practical ways that the IRS could improve public access to this important dataset. 

Among the group’s top concerns is missing data on billions of dollars in grants made by private foundations and public funders. Candid, a member of the Collective, has identified over 2,000 cases in which there is no, or only partial, grants data in the Form 990 and 990-PF XML files for FY 2019-2024. This concern was first raised with the IRS in 2023 and remains unresolved.

 “Data on grants is not only crucial for determining legal compliance,” the comments state. “If information on grantmaking is missing, the public lacks the transparency needed to track billions of charitable dollars, leaving donors, lawmakers, tax-exempt organizations, state charity regulators, scholars and others in the dark about how tax-exempt money is being used for the public good.”

The group urges the IRS to regularly release 990 forms, and to provide access to complete, machine-readable 990 data, so the public can easily use this information for transparency, compliance, charitable giving decision-making and other purposes.

Additional recommendations include: 

1. 990 Data Access, Usability, and Efficiency: The comments state that that the IRS has made strides in some areas. The Tax Exempt Organization Search (TEOS) Improvements page includes information that the Collective has long sought, such as 990 schema, data dictionaries and more. Building on this progress, the comments put forth a series of additional improvements that would greatly cut down on the work and expense associated with accessing and using 990 data.
2. Reporting of Government Revenue: The government is one of the largest funders of nonprofit activity in the United States, yet today it is impossible to determine the extent and details of nonprofit government revenue due to modifications made to the Form 990 in 2008.  The comments propose clarifying the reporting of government revenue on the Form 990, and other modifications. 

The bottom line: complete and accessible 990 data is a public good. It supports scholars and journalists, guides donors and institutional funders, and allows communities to understand how charitable dollars address pressing needs. 

See here for the full set of comments, which were signed by Candid, Charity Navigator, DataLake Nonprofit Research,  Do Good Institute at the University of Maryland, Dorothy A. Johnson Center for Philanthropy at Grand Valley State University, Independent Sector,  Minnesota Council of Nonprofits,  National Committee for Responsive Philanthropy,  The Nonprofit Alliance, as well as prominent nonprofit scholars in the United States writing in their individual capacities.

About the Nonprofit Open Data Collective

The Aspen Institute’s Nonprofit Open Data Collective advocates for accessible, timely data on nonprofit organizations and philanthropy in the United States.  Its members include researchers, nonprofit organizations, charity platforms, and others working to realize the full potential of the 2019 open 990 data law – a bipartisan policy that was championed by the Aspen Institute and its partners.