Form 8872 Instructions: Schedules A and B, E-Filing, and Penalties

Form 8872 is the report that Section 527 political organizations — parties, candidate committees, and PACs — use to publicly disclose the contributions they take in and the expenditures they make.¹ These instructions walk through who has to file, which reporting schedule to pick, how to complete the identifying section and Schedules A and B, how to reconcile the summary, and how to submit the return electronically. The form is separate from the annual income tax return (Form 1120-POL) and from any required annual information return (Form 990 or 990-EZ).² Late or incomplete filings carry a penalty of 21% of the contributions and expenditures involved, so accuracy is not optional.³

Who Has to File

Every tax-exempt political organization described in Section 527 of the Internal Revenue Code must file Form 8872 unless a specific exception applies.⁴ The obligation is tied to Form 8871, the initial notice of Section 527 status. An organization that reasonably expects annual gross receipts to always stay under $25,000 is not required to file Form 8871, and without that filing there is no Form 8872 requirement either. Once receipts cross $25,000, the organization has 30 days to file Form 8871 and must begin filing Form 8872 going forward.⁵

There is one important boundary. A qualified state or local political organization (QSLPO) is excepted from Form 8872 if all four of these are true: its exempt functions are aimed solely at state or local elections or offices; a state law requires it to report information similar to Form 8872; it actually files those reports with the state; and both the state and the organization make the reports open to public inspection in the same way Form 8872 would be.⁶ If any of those four conditions fails, the federal filing requirement is back on.

Picking a Reporting Schedule

Form 8872 offers two reporting schedules, and the choices depend on whether the year is an election year. For this form, an election year is any even-numbered year.⁷

In even-numbered years, you file either monthly or quarterly. In odd-numbered years, you file either monthly or semi-annually. Whichever schedule you pick, you stay on it for the entire calendar year; you cannot switch mid-year.⁷

Quarterly reports are due by the 15th day after the end of each calendar quarter, except that the fourth-quarter report is due January 31 of the following year rather than January 15.⁸ In an election year, quarterly filers must also file a pre-election report and a post-general election report.⁹

Monthly reports are due by the 20th day after the end of the month they cover. In an election year, no monthly reports are filed for October or November; the pre-election and post-general election reports take their place. December’s activity is captured on a year-end report due January 31 of the following year.⁷

Watch the pre-election report closely. It must be filed by the 12th day before the election if filed electronically, or by the 15th day before the election if sent by certified or registered mail, and it has to cover all reportable activity through the 20th day before the election.⁶ Any deadline that falls on a weekend or legal holiday shifts to the next business day.

Completing the Identifying Section

The top of Form 8872 collects the organization’s basic details. Enter the full legal name, mailing address, and Employer Identification Number. The EIN must match exactly what was reported on Form 8871; a mismatch can delay processing or trigger a rejection.

You also list two people: the custodian of records and the contact person. These can be the same individual. The form asks for the date the organization was formed and an email address for IRS correspondence.

Check the box that describes the filing: initial report, amended report, final report, or change of address. If you moved since the last filing, check “Change of address” in addition to whichever report type applies. The “Final report” box is used when terminating the organization, addressed further below.

Itemizing Contributions on Schedule A

Schedule A requires you to list each contributor whose aggregate contributions during the calendar year reach at least $200 as of the end of the current reporting period, provided at least some portion of those contributions was accepted during the reporting period you are filing for.⁶ The $200 figure is cumulative. Ten $25 gifts from the same person add up to $250 and trigger itemization.

For each itemized contributor, report:

Full name and mailing address.
Employer name. For individuals, list the employer, not a supervisor. Enter “Self-employed” if applicable, or “Not employed” if the contributor has no employer. For non-individual contributors such as another organization, enter “N/A.”
Occupation. Use the principal job title. For unemployed individuals, use a descriptive label such as “Retired,” “Student,” or “Homemaker.” For non-individuals, enter “N/A.”
Amount of each contribution. If a contributor gave more than once during the reporting period, report each contribution separately.
Aggregate year-to-date total from that contributor through the end of the reporting period.⁶

In-kind contributions — non-cash donations of goods or services — are reported at fair market value. Transfers of funds from another political organization also go on Schedule A and follow the same itemization rules.

Itemizing Expenditures on Schedule B

Schedule B mirrors Schedule A on the spending side. List each recipient to whom the organization made expenditures totaling at least $500 during the calendar year as of the end of the current reporting period, if any of those expenditures were made during this period.⁶

For each itemized recipient, report:

Full name and mailing address.
Employer name and occupation, following the same rules as Schedule A. Individual recipients need both; non-individuals get “N/A.”
Amount of each expenditure. Report each separately, and include in-kind expenditures at fair market value.
Purpose. Describe what the money bought. Be specific. “Printing services for mail campaign” or “Consulting fees for voter outreach” is far better than “Campaign services.”⁶

Expenditures below $500 do not need individual entries but still have to be included in the summary totals. Sloppy tracking of small expenditures is one of the most common ways an organization ends up with a summary that does not reconcile, and that is exactly the kind of error that attracts a penalty notice.

Completing the Summary Section

The summary ties together the totals from both schedules and calculates the organization’s cash position for the period. Enter the total itemized contributions from Schedule A, the total itemized expenditures from Schedule B, and the totals for non-itemized contributions and expenditures that fell below the $200 and $500 thresholds.

Next comes the cash balance at the beginning of the reporting period. Add total contributions, subtract total expenditures, and arrive at the ending cash balance. That ending balance must match the organization’s internal financial records. If it does not, reconcile before filing. A mismatch between Form 8872 and your bank records gets worse over time, not better.

Filing Electronically

All Forms 8872 covering periods that began on or after January 1, 2020, must be filed electronically; paper filing is no longer accepted for these periods.¹⁰ Before you can e-file Form 8872, you have to complete a one-time setup:

File Form 8871 electronically. This is the initial notice of Section 527 status.
Submit Form 8453-X. After electronically submitting Form 8871, an authorized official prints, signs, dates, and mails Form 8453-X (Political Organization Declaration for Electronic Filing) to the IRS at Ogden, UT 84201.¹¹
Receive your credentials. Upon receipt of Form 8453-X, the IRS mails a username and password to the organization. Those credentials let you file Form 8872 electronically and amend or finalize Form 8871.¹¹

An electronic submission is not complete until the IRS system returns a confirmation number. Keep that number. It is your proof of timely filing if a penalty dispute comes up later.

Penalties for Late or Incomplete Filing

The IRS imposes a penalty if an organization required to file Form 8872 fails to file by the due date, files but omits required information, or reports incorrect information. The penalty equals 21% of the total contributions and expenditures to which the failure relates.³ The rate is tied to the corporate tax rate under Section 11(b) of the Internal Revenue Code, referenced by Section 527(j).¹²

The penalty applies to the amount involved in the failure, not to the entire budget. If you filed on time but omitted $50,000 in contributions from Schedule A, the penalty would run against that $50,000. Even so, 21% of an unreported amount can climb fast during election season.

If you receive a penalty notice, you can request relief by submitting a written statement explaining the circumstances that prevented timely or complete electronic filing. The statement has to set out the specific facts that caused the failure and include the date of any attempted paper filing. The IRS evaluates these requests under a reasonable-cause standard: whether the organization took reasonable steps to comply and was blocked by circumstances outside its control.³

Filing a Final Report When Terminating

When a political organization shuts down, it has two obligations. First, file a final Form 8872 with the “Final report” box checked, covering all remaining contributions and expenditures through the termination date. Second, because termination is a material change, file a final Form 8871 within 30 days of termination.¹³

Skipping the final Form 8871 has a real cost. Any income the organization receives after the material change, including contributions, becomes taxable if the amended notice was not filed.¹⁴ Organizations winding down after an election cycle sometimes overlook this because the operational focus has moved on. Put the 30-day deadline on the calendar the moment the decision to terminate is made.

1
Internal Revenue Service. Periodic Reports – Form 8872
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Internal Revenue Service. FAQs About the Annual Form Filing Requirements for Section 527 Organizations
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Internal Revenue Service. Form 8872 – Penalties
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Internal Revenue Service. About Form 8872, Political Organization Report of Contributions and Expenditures
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Internal Revenue Service. Instructions for Form 8871
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Internal Revenue Service. Instructions for Form 8872
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Internal Revenue Service. Form 8872 – When to File
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Internal Revenue Service. Form 8872 Due Dates – Quarterly Reports
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Internal Revenue Service. Instructions for Form 8872
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Internal Revenue Service. Recent Legislation Requires Tax-Exempt Organizations to E-File Forms
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Internal Revenue Service. Form 8871 – Electronic Filing Required
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Office of the Law Revision Counsel. 26 USC 527 – Political Organizations
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Internal Revenue Service. Form 8871 – Final Report
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Internal Revenue Service. Audit Technique Guide – Political Organizations – IRC Section 527