IRS revises process for 501(c)4s ahead of midterms

The Internal Revenue Service changed the submission process earlier this week for groups that intend to operate as 501(c)4 tax-exempt organizations, requiring them to submit their forms electronically through Pay.gov, a move that could have political ramifications ahead of the midterm elections.

Starting March 9, 2026, Form 8976, Notice of Intent to Operate Under Section 501(c)(4), must be submitted electronically through Pay.gov, the IRS announced in an email last Friday. The IRS has been moving to make more of its forms available to be submitted electronically under its Digital First initiative. However, in this case, the move could have implications for political groups, many of which file for 501(c)4 tax-exempt status. A scandal erupted in 2013 after revelations that the IRS's Exempt Organizations unit had subjected 501(c)4 applications from some conservative and progressive groups to extra scrutiny ahead of the 2012 midterm elections, leading to the departures of several high-ranking IRS officials, including the director of the EO unit, Lois Lerner. The IRS later offered streamlined procedures for organizations to apply for tax-exempt status and in 2021 allowed them to file electronically through Pay.gov with a different form, Form 1024-A.

Form 8976 is used by an organization to notify the IRS that it is operating as a Section 501(c)(4) organization, as required by section 506 of the Internal Revenue Code. Until March 9, filers could submit Form 8976 electronically using the Electronic Notice Registration System. Form 8976 and the corresponding fee can only be completed and submitted electronically. There is no paper form.

The IRS said a user fee of $50 is required when submitting Form 8976. Filers must now pay the user fee through Pay.gov when submitting Form 8976. Payments can be made directly from a bank account, credit or debit card.

The IRS said filers that used the Electronic Notice Registration System will have 30 days from March 9, 2026 to retrieve copies of their past Form 8976 filings from that system. Copies of Form 8976 filings will still be available from the IRS after that date, but not through the Electronic Notice Registration System.

Updates about Form 8976 can be found by subscribing to EO Update, a free e-newsletter from the IRS Exempt Organizations and Government Entities function. EO Update includes information on tax policy, services and information that's important to tax-exempt organizations including:

• News releases from the IRS related to exempt organizations;
• New forms, guidance and other publications;
• Changes and additions to the IRS Charities and Nonprofits website; and
• Upcoming IRS training and outreach events

For more information, organizations can download Publication 557, Tax-Exempt Status for Your Organization, or contact IRS Customer Service.