IRS Forms

Form 8940 – Pay.gov Filing Guide for Exempt Organizations

Learn how to file Form 8940 on Pay.gov, build one 15 MB PDF, pay user fees, and request reclassification, 4945(g) approvals, set-asides, and TEOS listing.

Accountably Editorial Team 11 min read Dec 08, 2025 Updated Dec 08, 2025
A few filing seasons ago, I helped a small scholarship fund that nearly missed awarding aid because they did not know they needed advance approval for their 4945(g) scholarship procedures. The fix was not heroic, it was methodical, and it started with Form 8940.

If you have ever asked what to include, how to format the PDF, and where to submit it, this guide keeps you on track and helps you avoid the expensive do‑over.

Remember this first, you must file Form 8940 electronically on Pay.gov, not by mail. One combined PDF, up to 15 MB, and you pay the user fee inside Pay.gov before you submit.

Key Takeaways

  • Form 8940 is for “miscellaneous determinations” about an existing exempt organization, not for initial exemption. Common uses include reclassifying foundation status under section 509, advance approval for 4945(g) scholarship procedures, unusual grants, set‑asides, voter registration under 4945(f), and specific notices under section 507.
  • You must file on Pay.gov, and you must upload one combined PDF that includes Form 8940, all schedules, and all attachments, size limit 15 MB. Paper filings are returned.
  • Canadian registered charities and certain government entities also use Form 8940, for TEOS Publication 78 listing or voluntary termination of 501(c)(3) status.
  • Processing is trackable. For requests submitted on or before March 7, 2025, the IRS reports issuing 80 percent of Form 8940 determinations within about 215 days. Check the “Where’s My Application” page for current dates.
  • Fees change. As of filings on or after July 1, 2024, the user fee for set‑asides, 4945(g) procedures, and voter registration approvals increased to $3,500. Always confirm the current fee on the day you file.

What Form 8940 Is Used For

Think of Form 8940 as the IRS’s front door for targeted rulings and notices you cannot address with Form 1023 or your annual return. You will use it to handle reclassification between private foundation and public charity, to secure advance approvals for private foundation activities, to request a 990 filing exception, and to file certain termination notices. The IRS now lists twelve request types that must use Form 8940, all submitted through Pay.gov.

Use Form 8940 when you need the IRS to make or confirm a determination that affects how your exempt organization is classified or allowed to operate.

Examples you can file through 8940 include, reclassify from private foundation to public charity under section 509, obtain or change Type for a 509(a)(3) supporting organization, secure advance approval of scholarship procedures under 4945(g), request unusual grant treatment, request approval of set‑asides or voter registration activities, give notice for a 60‑month termination, ask for a 990 filing exception, and, for Canadian filers, seek TEOS Publication 78 listing and a U.S. public charity classification.

Who Should File Form 8940

You should file if you are already exempt under section 501(a) and need a specific determination or confirmation, if you are a nonexempt charitable trust seeking 509(a)(3) supporting organization status, if you are a government entity voluntarily terminating 501(c)(3) recognition, or if you are a Canadian registered charity seeking TEOS Publication 78 listing or U.S. public charity classification.

Situations That Trigger Filing

  • You plan to award scholarships from a private foundation and need 4945(g) advance approval before you start.
  • You want an unusual grant ruling so a major gift does not wreck your public support test.
  • You need to reclassify to public charity under 509(a)(1), 509(a)(2), or 509(a)(3), and you want IRS confirmation.
  • You are giving the IRS notice of a 60‑month termination under section 507(b)(1)(B).
  • You are a Canadian registered charity asking to be included in TEOS and Publication 78, and possibly to be treated as a public charity rather than a private foundation.

A Quick Word On Delivery And Control

Form 8940 is not hard, but the process is strict. The IRS now returns paper submissions and can return substantially incomplete electronic submissions along with your user fee. That means your internal workflow matters as much as your tax knowledge. Put another way, clean workpapers, consistent file naming, and proof that matches your request will save weeks.

At Accountably, we support CPA and nonprofit teams on the production side, for example, assembling one clean, bookmarked PDF that follows the IRS order, keeping exhibits searchable, and making sure the 15 MB limit is respected. You stay the signer and the decision maker. We provide the structure so your review time drops and your submission lands right the first time.

Electronic Filing On Pay.gov, Step By Step

You cannot mail Form 8940. The IRS moved the process online and made Pay.gov the exclusive path, with a short transition period that ended back in 2023. Today, the steps are simple, set up or sign in on Pay.gov, search for “8940,” open the form, complete the fields, upload your one combined PDF, pay the user fee, and save your confirmation.

The One‑PDF Rule, Why It Matters

Pay.gov accepts one uploaded file for Form 8940. The IRS instructions also tell you to consolidate everything into a single, legible, preferably searchable PDF. Over the size limit, the upload fails, and your submission stalls. Before you log in, plan your merge and confirm your final file is 15 MB or less.

Put your organization name and EIN on each page, use bookmarks that match your table of contents, and stick to the documents that actually apply to your request.

Pay.gov Filing Flow

  • Create or sign in to your Pay.gov account, then search “8940” and select the form.
  • Fill in all fields, check your EIN, and keep SSNs out of every attachment.
  • Upload your combined PDF, ≤15 MB, then pay the user fee by ACH, debit, or credit card.
  • Save the Pay.gov confirmation and receipt, they are your proof of filing and payment.

What The IRS Will Not Accept

The EO determinations program now returns paper submissions and will return substantially incomplete electronic filings. If you use the wrong form version, miss the fee, or leave out a required element like a conformed organizing document, expect a rejection with your fee sent back. Avoid the rework by using the current instructions and the user fee list that applies on your filing date.

What To Include, A Practical Checklist

The IRS instructions for Form 8940 list the components of a complete request and include an “attachments” section that reads like a ready‑made assembly guide. Use it. Put Form 8940 first, then the governing documents, then schedules and narratives, then any power of attorney forms. Keep it in that order, and make it searchable if possible.

Common Attachment Checklist

  • Form 8940 completed on Pay.gov, with an authorized officer’s signature, see the IRS signature guidance update if you plan to include a scanned signature page inside your PDF.
  • Organizing documents and all amendments, then bylaws and amendments.
  • Schedule A to Form 990, with public support computations, if you are seeking a 509(a)(1) or 509(a)(2) position or other support‑based request.
  • Financial statements and any 990 or 990‑PF schedules that support your request.

Board minutes or resolutions approving the action.

  • Narrative explanations and cross‑referenced exhibits.
  • Form 2848 or Form 8821 if you want the IRS to speak with your representative.

Formatting Tips That Speed Review

  • Use clear exhibit names, for example, Exhibit C, Scholarship Policy.
  • Add bookmarks, one per exhibit, and mirror that in a one‑page table of contents.
  • Use OCR so your PDF is searchable, it helps the specialist jump to the right page.
  • Keep only what the request type needs, which helps stay under 15 MB.

The Submission Steps, At A Glance

Step What You Do Pro Tip
1 Create or sign in to Pay.gov, search “8940,” open the form Use your organization email for account recovery
2 Complete fields, verify EIN, no SSNs anywhere Match names and EIN on every page
3 Upload the single combined PDF, ≤15 MB Bookmark exhibits and label pages
4 Pay the user fee and submit Save the Pay.gov confirmation and receipt
5 Track status on “Where’s My Application” Check the date cutoffs before calling the IRS

This sequence matches current IRS guidance and keeps your filing clean and traceable from start to finish.

User Fees, Effective Dates, And Payment

You cannot submit a Form 8940 request without paying the correct user fee inside Pay.gov. The IRS updates Exempt Organizations fees through the annual revenue procedure and announcements in the Internal Revenue Bulletin. One change that trips people up, filings on or after July 1, 2024 for 4942 set‑asides, 4945(g) scholarship procedures, and 4945(f) voter registration approvals carry a $3,500 fee, up from $2,500 for earlier submissions. Confirm the fee on the IRS TE/GE user fees page on your filing date.

Pay.gov accepts ACH, debit, and credit card payments. You will not be able to submit the form until the fee is authorized. Save the receipt.

If You Think The Fee Is Wrong

The IRB describes how to request reconsideration of a user fee in limited situations. If you believe the fee charged is inapplicable or incorrect, you can ask for reconsideration per the current EO revenue procedure. This is niche, but useful when you spot a mismatch.

Common Determination Requests Covered

These are the twelve types listed on the IRS Form 8940 page. If your issue is not on this list, check whether it needs a private letter ruling instead.

  • Advance approval of private foundation set‑asides, section 4942(g)(2).
  • Advance approval of private foundation voter registration activities, section 4945(f).
  • Advance approval of scholarship or grant‑making procedures, section 4945(g).
  • Exemption from Form 990 filing requirements, when allowed.
  • Advance determination that a potential grant is an unusual grant.
  • Change in, or initial determination of, Type of a 509(a)(3) supporting organization.
  • Reclassification of foundation status, including voluntary change to private foundation.
  • Notice only, intent to terminate private foundation status under section 507(b)(1)(B).
  • Termination of private foundation status under section 507(b)(1)(B), advance ruling request.
  • Termination of private foundation status under section 507(b)(1)(B), 60‑month period ended.
  • Voluntary termination of 501(c)(3) recognition by a government entity.
  • Canadian registered charities, TEOS Publication 78 listing and, if needed, U.S. public charity classification.

A Special Note On Exempt Operating Foundations

If a private foundation wants recognition as an exempt operating foundation, the IRS explains that you request a determination and pay the user fee. The requirements are strict, and you will support the request through Form 8940 with specific governance and support facts. Review the IRS definition and checklist before you file.

Reclassification And Public Charity Status Changes

Changing how the IRS classifies your organization, for example, from private foundation to public charity, requires a formal determination. Expect to include Schedule A to Form 990 with computations, your financials, your organizing document and bylaws, board minutes, and a short narrative that connects your donor mix and program model to the Code section you claim. Package it in one PDF, then submit and pay on Pay.gov.

Evidence That Speeds Review

  • Public support math on Schedule A with tie‑outs to your financials.
  • Clear statements about large donors and how you track unusual grants.
  • Board minutes that show the governing body approves the change and understands the reason.
  • Exhibit names that match your narrative, so a specialist can verify facts in minutes.

Canadian Registered Charities, What To Know

If you are a Canadian registered charity and you want U.S. donors to find you in TEOS, you will file Form 8940 on Pay.gov. You will need an EIN, not an SSN, and you must include your governing documents, CRA registration proof, an activities description, and a classification analysis that explains why you should be treated as a U.S. public charity rather than a private foundation. The Form 8940 page lists this request type and confirms the same one‑PDF and user fee rules apply.

Treat this like a full determination package. One file, one fee, one Pay.gov submission, then monitor status in the IRS tool.

Tracking Your Application And When To Call

After you submit and pay, switch to monitoring. The IRS “Where’s My Application” page shows date cutoffs for each form, including 8940, and tells you when to wait and when to reach out. As of the page dated in 2025, for 8940 requests submitted on or before March 7, 2025, the IRS issued 80 percent of determinations within about 215 days. If you filed after the posted cutoff, the case may not be assigned yet, so wait to call.

Keep the Pay.gov confirmation handy. If your PDF was too large or the payment did not post, fix the file, compress scans, remove nonessential pages, and resubmit, then contact the IRS only when the page says it is time. The EO determinations program emphasizes that it will now return substantially incomplete applications, so precision up front protects your timeline.

Privacy, Security, And System Notices

Pay.gov is a Treasury system. Treat every attachment as sensitive and keep SSNs out of your package. The IRS instructions, along with the Pay.gov form page, make clear that you submit online, you pay online, and you should not mail anything. Close your browser when you finish, secure your local files, and keep a copy of the final PDF and the Pay.gov receipt in your records.

Before You Begin, A Pre‑Flight List

Confirm your request type, gather every exhibit, and draft a one‑PDF plan before you open Pay.gov. Small gaps cause big delays.

  • Verify your EIN and authorized signer, then keep SSNs out of all attachments.
  • Match your request to the IRS list of 8940 request types, do not guess.
  • Assemble one searchable PDF, ≤15 MB, with Form 8940 first, then exhibits in the IRS order.
  • Check the current user fee. The 4942 set‑aside, 4945(g), and 4945(f) fees are $3,500 for filings on or after July 1, 2024. Confirm the number the day you file.
  • If you need to include a scanned signature page, follow the IRS update on acceptable e‑sign methods for Form 8940 PDFs.

Where Accountably Fits, Without Losing Control

You may not need outside help for tax positions, but you might want help on production quality. Our team at Accountably works inside your systems to standardize workpapers, keep exhibit names and versions clean, and assemble the single PDF under 15 MB with bookmarks that match the instructions. You stay in charge of tax positions, strategy, and signing. We handle the disciplined execution, which is where most 8940 delays start. This keeps your partner time focused on analysis while the mechanics move on schedule.

FAQs

What is IRS Form 8940 in plain language?

It is the form you use to request IRS determinations about an existing exempt organization, for example, reclassifying foundation status, getting advance approval for scholarship procedures, or requesting a 990 filing exception. You file it on Pay.gov and upload one combined PDF with all attachments.

Do I mail anything or pay by check?

No. The IRS will return paper submissions and will not process substantially incomplete applications. You must submit and pay electronically on Pay.gov.

How long will it take?

Timelines vary by request type and IRS workload. For requests submitted on or before March 7, 2025, the IRS reports issuing 80 percent of Form 8940 determinations within about 215 days. Use “Where’s My Application” to check the current dates.

What are the current fees for advance approvals?

For filings on or after July 1, 2024, the fee for 4942 set‑asides, 4945(g) scholarship procedures, and 4945(f) voter registration approvals is $3,500. Always confirm the current fee on the IRS user fees page before you submit.

Can I request expedited handling?

Yes, in limited circumstances such as a pending grant that would harm operations if delayed, disaster relief, or IRS error. If approved, your request moves ahead in the queue for assignment, it does not guarantee an approval.

Are Forms 940 and 941 related to Form 8940?

No. Those are employment tax forms. Form 8940 is strictly for exempt organization determinations. Keep payroll and EO workflows separate.

How do I sign if I am submitting electronically?

The IRS allows a practical method. Include a copy of the handwritten signature of the authorized official inside the PDF you upload, following the IRS guidance on signing electronically submitted Form 8940.

Conclusion And Next Steps

Treat Form 8940 like a repeatable workflow. Pick the correct request type, build one clean, bookmarked PDF that follows the IRS order, file and pay on Pay.gov, then track your status in the IRS tool. If your facts are complex, bring in counsel early and keep your narrative short and precise. That is how you minimize questions and keep your determination moving.

If you want help with the production side, our team at Accountably can standardize exhibits, version control, and formatting so your PDF fits the 15 MB limit and your reviewer finds everything fast. You keep the relationship, the strategy, and the signature. We bring capacity without chaos.

Compliance note, this article reflects IRS pages last reviewed by the IRS between March and April 2025 and was prepared on December 8, 2025. Always recheck the IRS “About Form 8940,” instructions, user fees, and “Where’s My Application” pages before you file.

Every Form Represents Work Your Team Has to Deliver

Accountably embeds trained offshore teams into your workflow – so your firm handles more returns without more burnout.

30-Day Guarantee 150+ Firms SOC 2 Aligned