# Public Disclosure Requirements for Booster Clubs: What to Share

> Which documents a booster club must show anyone who asks: its last three annual returns, Form 1023 and the IRS letter, Form 990-T, deadlines, and penalties.

- URL: https://boosterclub.org/taxes/public-disclosure/
- Section: Taxes
- Updated: 2026-10-06

A booster club with 501(c)(3) status, the federal tax exemption for charitable and educational organizations, must let anyone inspect and copy its exemption application and its last three annual returns, under section 6104(d) of the Internal Revenue Code (IRC). The requester does not have to be a member, a parent, or a donor, and the club must respond within set deadlines or face daily penalties.

Requests come from parents, reporters, district staff, grant makers, and occasionally former officers in a dispute. The secretary keeps a public disclosure folder ready, and the president or a designated officer responds. A club that posts the documents online can point requesters to the posting instead of making copies.

## What Must Be Disclosed

| Document | What is included | How long |
|---|---|---|
| Exemption application | Form 1023 or 1023-EZ, all supporting documents, and any letter or document the Internal Revenue Service (IRS) issued about the application, including the determination letter | No three-year limit |
| Annual returns | Form 990 or 990-EZ, with all schedules, attachments, and supporting documents, and any amended return | Three years from the later of the due date (including extensions) or the date actually filed |
| Form 990-T | The club's unrelated business income tax return, if filed; schedules unrelated to that tax are not required | Three years from the due date, including extensions |

What the club does not have to disclose:

- **Donor names and addresses.** A public charity filing Form 990 or 990-EZ does not disclose the names and addresses of contributors listed on Schedule B. Amounts and descriptions of gifts remain public unless they would identify the donor.
- **Older returns.** Returns past the three-year window. An amended return has its own three-year window starting when it is filed.

Form 990-N filings are published by the IRS in its Tax Exempt Organization Search, where anyone can view them. A club that files only Form 990-N should still keep each filing confirmation and its exemption application and determination letter ready, because those are the documents most often requested.

## Who Can Ask and How

Anyone may ask, for any reason. Requests may be made in person or in writing, including by mail, email, fax, or private delivery service. A written request must give the address to send the copies to. A requester may ask for a whole document or a specific part, such as one schedule.

During an in-person inspection the club may have someone present, must let the requester take notes, and must allow photocopying at no charge if the requester brings their own equipment.

## Response Deadlines

| Situation | The club must |
|---|---|
| In-person request at a principal office during business hours | Allow inspection and provide copies the same day |
| Unusual circumstances, such as a request beyond the club's capacity to copy that day | Provide copies by the next business day after the circumstances end, or the fifth business day after the request, whichever is first |
| Club with no permanent office (most booster clubs) | Make the documents available at a reasonable location within a reasonable time, normally no more than two weeks, or mail copies within two weeks |
| Written request | Mail copies within 30 days of receiving the request (or of receiving payment, if prepayment is required) |
| Written request without required prepayment | Notify the requester of the policy and amount due within 7 days |
| Requester agrees to email | Provide the copies by email |

A mailed request is treated as received seven days after its postmark unless there is evidence otherwise. An emailed or faxed request is received the day it is successfully sent.

## Fees for Copies

The club may charge a reasonable fee for copies, no more than the per-page rate the IRS charges, plus actual postage. For in-person requests, a club that charges must accept cash and money orders. For written requests, it must accept certified checks, money orders, and either personal checks or credit cards. A club without a permanent office may charge for copying and postage only if the requester agrees to the charge.

Emailing a PDF at no charge, with the requester's agreement, ends most requests quickly and avoids disputes.

## The Widely Available Exception

A club that makes its application and returns widely available does not have to respond to individual requests for copies, though it must still allow in-person inspection. A document is widely available when:

1. It is posted on a web page the club maintains, or in an online database of similar documents maintained by another entity;
2. The page tells readers the document is available and how to download it;
3. The posted file exactly reproduces the document as filed with the IRS, except for information the law allows to be withheld; and
4. Anyone can view, download, and print it free, without special software.

The club must then tell each requester where the documents are posted: immediately for in-person requests, and within the deadline for written ones.

## Penalties

| Failure | Penalty |
|---|---|
| Not allowing inspection or providing copies of an annual return | $25 per day, up to $13,000 per return |
| Not allowing inspection or providing copies of the exemption application | $25 per day, no maximum |
| Willful failure | An additional $5,000 under section 6685 |

These amounts come from the 2025 Form 990-EZ instructions and Revenue Procedure 2025-32, and are adjusted for inflation. IRS Publication 4221-PC, last revised in 2018, still shows the older $20 per day and $10,000 figures. The penalty applies to the person responsible for the failure, which in a booster club is usually an officer.

## Building the Disclosure Folder

1. Gather Form 1023 or 1023-EZ, every attachment, all IRS correspondence about the application, and the determination letter. If the letter is lost, request an affirmation letter from IRS Customer Account Services by phone, letter, or fax, signed by an officer.
2. Add the last three annual returns with all schedules, and any Form 990-T.
3. Remove donor names and addresses from the public copy of Schedule B.
4. Confirm no Social Security numbers appear anywhere; IRS Publication 4221-PC warns against including personal identifying information on public forms.
5. Post the folder's PDFs on the club's website with a short download note, if the club chooses the widely available route.
6. Name the officer who responds, and keep a log of requests and responses.
7. Each year, add the new return and retire the one that has passed its three-year window, keeping the retired copy in the permanent records.

## What Parents May Ask for Beyond Federal Rules

Parents often ask for bank statements, the budget, or minutes. Federal disclosure rules do not require those, but the bylaws or state nonprofit law may give members inspection rights, which vary by state. A club that shares treasurer's reports at every meeting and posts its annual return rarely gets hostile requests. See [The Monthly Treasurer's Report](https://boosterclub.org/finance/treasurer-report/) and [Booster Club Records and Document Retention](https://boosterclub.org/governance/records/).

## Common Mistakes

- **Refusing because the requester is not a member.** Federal law gives the right to anyone, and the refusal starts the daily penalty.
- **Handing over Schedule B with donor names.** Contributor names and addresses are not public, and disclosing them can damage donor trust.
- **Not knowing where the 1023 is.** The application has no three-year limit, and many clubs lost it two treasurers ago.
- **Ignoring an email request.** A written request includes email, and the 30-day clock is running.
- **Posting a retyped summary instead of the filed return.** The widely available exception requires an exact image of what was filed.

## Checklist

- [ ] Locate Form 1023 or 1023-EZ, its attachments, and the determination letter, or request an affirmation letter (secretary)
- [ ] Collect the last three annual returns with schedules, and any Form 990-T (treasurer)
- [ ] Remove donor names and addresses from the public copy of Schedule B (treasurer)
- [ ] Check every page for Social Security numbers or other personal information (secretary)
- [ ] Post the documents on the club website with download instructions, if choosing the widely available route (secretary)
- [ ] Designate the officer who responds to requests and record it in the minutes (board)
- [ ] Log every request with the date received and the date fulfilled (secretary)
- [ ] Respond to in-person requests the same day and written requests within 30 days (designated officer)
- [ ] Add each new return and retire returns past the three-year window every year (secretary)

## Related Pages

- [Booster Club Records and Document Retention](https://boosterclub.org/governance/records/) for the permanent file
- [A Booster Club Website](https://boosterclub.org/marketing/website/) for posting the 501(c)(3) letter and returns
- [How to File Form 990-EZ for a Booster Club](https://boosterclub.org/taxes/form-990-ez/) for Schedule B and what the return shows
- [How to Get 501(c)(3) Status for a Booster Club](https://boosterclub.org/start/501c3/) for the application that must be disclosed
- [Booster Club Compliance Calendar](https://boosterclub.org/taxes/compliance-calendar/) for the yearly folder update

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*This page is general information for volunteer-run booster clubs. It is not legal,
tax, or accounting advice, and BoosterClub.org is not a law firm, accounting firm, or
government agency. Rules change and vary by state and district. Confirm current
requirements with the IRS, the relevant state agency, the school district, and a
qualified professional before acting. If a fact on this page is out of date, we want
to know.*

## Sources

1. IRS: https://www.irs.gov/charities-non-profits/public-disclosure-and-availability-of-exempt-organizations-returns-and-applications-documents-subject-to-public-disclosure
2. IRS: https://www.irs.gov/instructions/i990ez
3. IRS: https://www.irs.gov/pub/irs-pdf/p4221pc.pdf
4. IRS: https://www.irs.gov/pub/irs-drop/rp-25-32.pdf
5. IRS: https://www.irs.gov/charities-non-profits/annual-electronic-filing-requirement-for-small-exempt-organizations-form-990-n-e-postcard
6. IRS: https://www.irs.gov/charities-non-profits/exempt-organizations-affirmation-letters