‘Responsible Party’ Requirement for IRS Non-Profit Filings

As a reminder, non-profit organizations are required to have on file a ‘responsible party’ with the Internal Revenue Service. A ‘responsible party’ for a non-profit organization is considered to be the same as the principal officer for the organization as defined by the IRS in the Form 990 instructions. This is defined as the individual of the organization who has ultimate responsibility for “implementing the decisions of the organization's governing body, or for supervising the management, administration, or operation of the organization”.

If you are unsure who the IRS has on record as your organization’s ‘responsible party’, the IRS Tax Exempt and Government Entities Customer Account Services department can be contacted at (877) 829-5500 or you can check the IRS business master file (BMF) online Exempt Organizations Business Master File Extract (EO BMF) | Internal Revenue Service (irs.gov)

In order to update the your organization’s ‘responsible party’, your organization is required to file the IRS Form 8822-B, Change of Address or Responsible Party – Business within 60 days of any changes to your organization’s ‘responsible party’. While completing the IRS form 8822-B, the name and social security number of the ‘responsible party’ is required to be included on the form, unless the form is being completed by a governmental entity, which permits the government entity to use the organization’s EIN number in lieu of a social security number. The IRS Form 8822-B is also required to be filed for any of the following scenarios:

• Your business mailing address has changed
• Your business location has changed
• The identity of your ‘responsible party’ has changed

The IRS requirement to identify a ‘responsible party’ was initiated by the IRS in July of 2021 as a response to security issues, such as identity theft. For more information on IRS Form 8822-B, please refer to the IRS website.