Every year the I R S publishes what it costs the whole exempt sector to prove it is exempt. This morning’s number says there are twenty-four thousand fewer organizations filing — and one million two hundred thousand more hours going into it.

Somebody on your board has asked you what the 990 actually costs to produce. You probably answered with the accountant’s invoice, because that is the number you can see. It is the small half.

This morning the I R S published its Paperwork Reduction Act notice for the whole tax-exempt returns family — 990, 990-EZ, 990-PF, 990-T, every schedule and attachment behind them. Once a year the agency is required to estimate what that collection costs the people who have to comply with it, publish the estimate, and take comment. It is eight pages in the Federal Register, most of it a list of forms. The numbers are in the middle.

Those are the agency’s words, not a projection of mine: “Preliminary Estimated Number of Respondents,” “Preliminary Estimated Total Time (Hours),” “Preliminary Estimated Time per Respondent.” The dollar line runs alongside them — $4,358,787,000 of monetized time plus $2,134,343,000 out of pocket, which the notice adds to a Total Monetized Burden of $6,493,131,000.

Six and a half billion dollars is a number you can put in a newsletter and nobody will check it. So do the thing that makes it mean something: put last year’s notice next to it. The I R S publishes this every summer. The 2025 edition ran on July 25 under the same O M B control number, in the same format, with the same word — preliminary — in front of every figure.

Respondents, 2025 notice to 2026 notice. Twenty-four thousand fewer.

And the hours over the same twelve months went the other way: 74,890,000 → 76,091,000. That is 1,201,000 additional hours spread across fewer organizations. Per organization it reads as 43 hours 17 minutes last year against 44 hours 36 minutes this year — an extra hour and nineteen minutes each. The total monetized burden moved $6,180,000,000 → $6,493,131,000, up $313 million. The subtraction is mine; every figure in it is printed.

I am not going to tell you the sector is being crushed, because I do not know that from two lines of a notice, and neither does anyone else. Organizations dissolve. Filing thresholds move people between forms. A revision year adds schedules. The I R S says plainly that forms were added and removed.

What I will say is that this is the only place the trade-off is ever written down, and it points one way. Fewer of you. More hours. And the arithmetic that produced both is not shown.

Read that against what the same notice asks you to do. Comments are invited on, among other things, “(b) the accuracy of the agency’s estimate of the burden of the collection of information.”

So the sixty-day window — the long one, the one with your name on it — runs on figures the agency has told you are not final. The final ones arrive with the thirty-day notice, which is the short window, at Treasury, after this one closes. That is not a conspiracy. It is a sequence. But it is the sequence, and it decides who gets to say anything useful.

Here is the part I had to check twice. I pulled last year’s notice expecting different wording. That “Current Actions” paragraph is word for word identical in the 2025 and 2026 notices — same sentences, same order, same promise that the real figures are coming with the 30-day notice. It is a standing paragraph. Which means the sixty-day comment period on the largest information collection the exempt sector faces has now run twice in a row on numbers the agency described, in advance, as unfinished.

Kept honest. Every figure on both sides of the comparison is labelled “Preliminary” by the I R S, and the 2026 notice says explicitly that the estimates “were not finalized at the time of release.” I am comparing preliminary to preliminary, which is the right comparison and still not a comparison of final numbers. The 2025 figures are round and the 2026 figures are not — last year’s hours and dollars are stated to the nearest million or five million, this year’s to the dollar — so treat the $313 million as a difference between two estimates of unequal precision, not as a measured change. I cannot tell you why respondents fell or why hours rose. The notice does not break the movement down, and I did not find a source that does; dissolutions, threshold changes and the added and removed forms the notice mentions could each account for part of it, in either direction. The per-organization figures are the agency’s own, and they divide cleanly — but an average across 1.7 million organizations spans a volunteer-run 990-N filer and a hospital system, so it describes no actual charity. “Fewer organizations” is not the same as fewer charities: this collection counts respondents to a family of forms, and a group that moves between form types or files in a different year moves the count without going anywhere. Finally, I could not read the comments already filed — there is no public docket for this collection, only an email address, so I cannot tell you whether anyone has responded to it in any year.

Sources, both primary and both fetched today, August 3, 2026. (1) Internal Revenue Service, Department of the Treasury, Agency Information Collection Activities; Comment Request on U.S. Tax-Exempt Organization Returns and Related Forms., 91 FR 48972–48979, FR Doc. 2026-15608, published August 3, 2026, dated July 29, 2026, signed Marcus W. McCrary, Tax Analyst — full text read today via the Federal Register plain-text service, 2026-15608.txt, with document metadata from the Federal Register JSON API per house rules for WAF-blocked origins. Source of: OMB Control Number 1545-0047; the title “U.S. Tax-Exempt Organization Returns and Related Forms, 990, 990-EZ, 990-PF, 990-T, and all related forms, schedules, and attachments”; “DATES: Written comments should be received on or before October 2, 2026 to be assured of consideration”; the comment address (Andres Garcia, Internal Revenue Service, Room 6526, 1111 Constitution Avenue NW, Washington, DC 20224, or by email to pra.comments@irs.gov with “OMB Control No. 1545-0047” in the subject line); “Comments submitted in response to this notice will be summarized and/or included in the request for OMB approval. All comments will become a matter of public record”; the five invited comment topics including “(b) the accuracy of the agency’s estimate of the burden of the collection of information”; “Type of Review: Revision of a currently approved collection”; “Affected Public: Tax-Exempt Organizations”; the “Current Actions” paragraph quoted in full above; and the six preliminary estimates — Respondents 1,706,000; Total Time 76,091,000 hours; Time per Respondent 44 hours, 36 minutes; Monetized Time $4,358,787,000; Out-of-Pocket Costs $2,134,343,000; Total Monetized Burden $6,493,131,000. (2) The prior-year notice for the same collection, IRS, Agency Information Collection Activities; Comment Request on U.S. Tax-Exempt Organization Returns and Related Forms, FR Doc. 2025-14070, published July 25, 2025 — located today by searching the Federal Register API for “1545-0047” restricted to the Internal Revenue Service, and read via the same plain-text service. Source of the 2025 comparators — Respondents 1,730,000; Total Time 74,890,000 hours; Time per Respondent 43 hours 17 minutes; Monetized Time $4,125,000,000; Out-of-Pocket Costs $2,055,000,000; Total Monetized Burden $6,180,000,000 — and of the fact that its “Current Actions” paragraph is identical, sentence for sentence, to the 2026 one quoted above. The differences (−24,000 respondents; +1,201,000 hours; +1 hour 19 minutes per respondent; +$313,131,000 total monetized burden) are my subtraction of the two published sets. No trade coverage supplied any fact in this edition; I found none on this notice.

The IRS published the exempt sector's annual paperwork bill this morning. Two lines in it moved in opposite directions.

1,730,000 organizations last year → 1,706,000 this year.
74,890,000 hours last year → 76,091,000 this year.

Twenty-four thousand fewer of us. One-point-two million more hours.

Here's what the document is. Once a year, under the Paperwork Reduction Act, the IRS has to estimate what it costs the people who file the 990 family — 990, 990-EZ, 990-PF, 990-T, every schedule behind them — to actually comply. Then it has to publish that estimate and take comment. It ran this morning at 91 FR 48972.

This year's estimate:

1,706,000 organizations. 76,091,000 hours. 44 hours 36 minutes each, per year, before anyone pays a preparer. $4.36 billion of monetized staff time, $2.13 billion out of pocket, $6.49 billion total.

Last year the same notice said 43 hours 17 minutes.

So the average organization is doing an extra hour and nineteen minutes, and there are fewer organizations to spread it across.

I can't tell you why. The notice doesn't break it down. Orgs dissolve, thresholds move people between forms, a revision year adds schedules — the IRS says forms were added and removed. Any of that could be part of it. I'm not claiming a crisis from two lines of a notice.

But this is the only place the trade-off gets written down at all, and it points one way.

Now the part that made me go back and re-read.

The notice asks for comment on, quote, "the accuracy of the agency's estimate of the burden of the collection of information."

And four paragraphs earlier it says this:

"It is anticipated that these changes will have an impact on the overall burden and cost estimates requested for this approval package, however these estimates were not finalized at the time of release of this notice. These estimated figures are expected to be available by the release of the 30-day comment notice from Treasury."

Every figure above is labelled Preliminary. Five times.

So the sixty-day comment window — the long one, the one the public actually gets — runs on numbers the agency has already told you aren't final. The final ones show up with the thirty-day notice, at Treasury, after this window shuts.

I pulled last year's notice expecting different wording.

That paragraph is word-for-word identical. Same sentences, same order, same promise. It's a standing paragraph.

Which means the long comment period on the biggest information collection this sector faces has now run two years running on figures described in advance as unfinished.

Comments are due October 2. There's no docket number and no regulations.gov page — it's an email address, pra.comments@irs.gov, with "OMB Control No. 1545-0047" in the subject line.

If you want to file something that actually lands, don't object. Measure. The agency asked whether 44 hours 36 minutes is right and it has almost no way to find out except by being told. If your org tracked the real staff hours on the 990 — not the preparer's invoice, the hours — that's a data point the estimate does not contain today. Name the form, state your size, give the number.

And one thing for your next board meeting: report compliance in hours, not in fees. Forty-four and a half hours is more than a working week out of somebody's year, and on a small team it's the person who also runs payroll and the gala. A board looking only at the invoice is seeing the smaller half.

Kept honest: every figure on both sides is labelled preliminary, and last year's are rounded where this year's aren't — so treat the $313 million gap as a difference between two estimates of unequal precision, not a measured change. It's a monetized burden, hours converted to dollars, not a bill anyone receives. And an average across 1.7 million filers spans a volunteer-run 990-N and a hospital system, so it describes no actual charity.

FIRST SOURCE · one verified original-source finding, composed for one reader · this edition: nonprofits and fundraising — written for the people who have to explain the 990 to a board that only ever sees the invoice