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The compliance field notes

A Different Checklist for Churches

Why a ministry’s compliance review should reflect its structure and activities.

A church, an affiliated ministry, and a separately organized religious nonprofit may have different responsibilities. Start with the actual organization rather than an assumption based on its mission.

Understand the organization first

Document the structure, leadership model, activities, and relationships with related entities. These facts are essential to a useful review.

Do not assume identical annual filings

Churches and certain related organizations are generally excepted from annual Form 990 filing. Other religious organizations may have filing obligations. Review the specific organization and applicable exception.

Look beyond a single form

A filing exception does not answer every governance, tax, employment, or recordkeeping question. Identify the areas requiring qualified review.

Make decisions traceable

Organize governing documents, leadership approvals, and relevant records. Ask whether the current process supports consistent, documented decisions.

Separate general support from specialist work

Clergy compensation, payroll, employment questions, and legal disputes may need specialized expertise. Define the work before accepting a generic package.

Continue with an official resource

IRS: Church and religious-organization filing requirements

General educational information. Requirements can change and depend on the facts and jurisdiction.

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Your obligations.
A practical next step.

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