Do Churches Have EIN Numbers? Payroll, Banking, and UBI

Yes, churches have EIN numbers, and nearly every church needs one. Churches are automatically recognized as tax-exempt under Section 501(c)(3) without filing an application, but that automatic status doesn’t remove the need for an Employer Identification Number. The IRS requires every exempt organization to have an EIN, even one with no employees.1Internal Revenue Service. Employer Identification Number Banks require it to open accounts, payroll filings run on it, donors want to see it on receipts, and grant programs won’t process applications without it.

The number itself is a nine-digit identifier that works like a Social Security number for the organization. It’s free, and the IRS issues it in minutes through the online application.

How a Church Gets an EIN

The fastest route is the free online application on irs.gov, which issues the number immediately.2Internal Revenue Service. Get an Employer Identification Number Churches can also apply by fax or mail using Form SS-4.3Internal Revenue Service. Obtaining an Employer Identification Number for an Exempt Organization On the application, select “church or church-controlled organization” as the entity type.1Internal Revenue Service. Employer Identification Number

The IRS never charges a fee for an EIN. Third-party sites sometimes charge $50 to $150 to submit the same free form on your behalf, and the IRS specifically warns applicants about them.2Internal Revenue Service. Get an Employer Identification Number If a website is asking for payment, you’re not on irs.gov.

Where the EIN Actually Gets Used

Bank Accounts

Banks and credit unions won’t open an account in the church’s name without an EIN. There is no workaround. A church that runs finances through a pastor’s personal Social Security number creates liability and reporting problems that only get worse with time.

Donation Receipts

Including the EIN on donation receipts reinforces the church’s status as a qualified tax-exempt organization and gives donors what they need for their own returns. Donors claiming charitable deductions are more likely to face IRS scrutiny when their receipts lack the organization’s EIN.

For a single non-cash gift worth more than $5,000, the donor has to file Form 8283, and the church must complete the donee acknowledgment section, which requires its EIN.4Internal Revenue Service. Form 8283, Noncash Charitable Contributions Without it, the donor can lose the deduction entirely. Churches receiving real estate, vehicles, or artwork need to be ready to complete their portion promptly.

Grants and Federal Funding

Private foundations and federal grant programs almost always require the EIN in the application. Federal funding goes further: direct federal awards generally require registration in SAM.gov, and that registration requires a Taxpayer Identification Number as part of the core data.5SAM.gov. Entity Registration Checklist For a U.S. church, that means its EIN. A church without one is disqualified before its application is read.

Payroll: Where the EIN Matters Most

Any church with employees files quarterly on its EIN, and the rules split hard between clergy and lay staff.

Lay Employees

Non-clergy staff are treated like employees anywhere else. Wages are subject to Social Security and Medicare taxes under FICA, with the church and the employee each paying half.6Internal Revenue Service. Publication 517, Social Security and Other Information for Members of the Clergy and Religious Workers The church withholds the employee’s share and reports everything on quarterly Form 941 filings under its EIN.

There is one exception. A church religiously opposed to paying FICA can elect out under IRC Section 3121(w).7Office of the Law Revision Counsel. 26 U.S. Code 3121 – Definitions If the church makes the election, it stops withholding FICA and stops paying the employer share; the employees then owe self-employment tax on their own returns. The election is irrevocable in practice, and the IRS revokes it automatically if the church fails to issue W-2s for two consecutive years.

Ordained Ministers

Ministers performing services in their ministerial capacity have an unusual dual status. They get a W-2 from the church, but the church does not withhold Social Security or Medicare from their pay. Ministers pay their own Social Security and Medicare through the self-employment tax system (SECA), on Schedule SE with their personal return.6Internal Revenue Service. Publication 517, Social Security and Other Information for Members of the Clergy and Religious Workers Nothing comes out of the paycheck, and the first-year self-employment tax bill can be substantial. Ministers who skip estimated payments through the year often face penalties.

Form 941 Deadlines

Every church with employees files Form 941 each quarter under its EIN:

  • Quarter 1 (January through March): due April 30
  • Quarter 2 (April through June): due July 31
  • Quarter 3 (July through September): due October 31
  • Quarter 4 (October through December): due January 31

Churches that deposit all payroll taxes on time get an extra ten days after each deadline to file.8Internal Revenue Service. Instructions for Form 941 State and local rules vary, and most states require employer registration within 15 to 30 days of the first hire.

Unrelated Business Income

Churches are exempt from income tax on activities tied to their religious mission. Income from unrelated business activities is treated differently. If a church earns $1,000 or more in gross income from an unrelated trade or business, it must file Form 990-T under its EIN and pay tax on that income.9Internal Revenue Service. Unrelated Business Income Tax

Common examples include renting a parking lot to weekday commuters, running a commercial bookstore open to the public, or operating a coffee shop that competes with local businesses. Rental income from real property is generally excluded, but the exclusion evaporates when the church provides substantial services to tenants, rents personal property alongside real property, or takes rent based on a tenant’s profits.10Internal Revenue Service. Exclusion of Rent From Real Property From Unrelated Business Taxable Income Renting the fellowship hall for weekend events is usually fine. Renting storage units or operating paid parking during business hours likely produces taxable income. If the expected tax is $500 or more, the church must also make estimated payments during the year.9Internal Revenue Service. Unrelated Business Income Tax

Churches Don’t File Form 990

One thing the EIN does not obligate a church to do is file the annual Form 990. Churches are specifically exempt from that return, and the exemption comes directly from federal statute, which lists churches, integrated auxiliaries, and conventions or associations of churches among the mandatory exceptions.11Internal Revenue Service. Annual Exempt Organization Return: Who Must File12Office of the Law Revision Counsel. 26 USC 6033 – Returns by Exempt Organizations Form 990-T for unrelated business income is a separate matter and is still required when it applies.

Group Exemption Churches Still Need Their Own EIN

Churches that belong to a denomination covered by a group exemption letter sometimes assume the central organization’s identifiers cover them. They don’t. The IRS requires every subordinate organization included in a group exemption to have its own EIN, even with no employees.13Internal Revenue Service. Group Exemptions The central organization must include each subordinate’s EIN on the list it submits, and it must submit a completed Form SS-4 on behalf of any subordinate that doesn’t have one yet. The group exemption streamlines the exemption itself; it does not centralize EINs. Each local church still operates as a separate entity for banking, payroll, and tax reporting.

What Happens if a Church Operates Without an EIN

The practical consequences stack quickly. Without an EIN, a church can’t open a bank account in its own name, can’t process payroll legally, can’t issue proper W-2s, can’t complete donation receipts fully, can’t sign Form 8283 for a large non-cash gift, can’t apply for grants, and can’t file Form 990-T if it generates unrelated business income.

Payroll is where the price gets steep. A church that pays employees without withholding and reporting payroll taxes faces penalties for each late or missing Form 941. The IRS can also assess trust fund recovery penalties against the individual church officers responsible for withholding. Those penalties equal 100% of the unpaid employment taxes and attach to the responsible person individually, not just the church.

Getting an EIN takes minutes and costs nothing. Untangling years of operating without one is neither quick nor cheap.