The policies you are actually asked for
There is no single checklist that settles every U.S. nonprofit’s obligations. Start with the organization’s activities, state, funding agreements, and legal form. Gather its articles, bylaws, and existing policies; ask counsel to resolve conflicts with applicable law rather than assuming a template or bylaw wins. Federal reporting is one part of this: the IRS explains that Part VI asks about governance policies generally not required by the Internal Revenue Code (opens in new tab).
Then identify the return you actually file. Form 990-EZ and Form 990-N are not the same questionnaire as Form 990, and some organizations have filing exceptions. Use the IRS annual-return overview (opens in new tab) with your preparer. A funder’s or insurer’s requested document is a separate requirement to check against that agreement.
Sources checked September 28, 2026. The policy-selection and register workflow below is an organizing suggestion, not a legal review of your organization.
| Policy | Who asks | Why it matters |
|---|---|---|
| Conflict of interest and disclosure | Form 990, Part VI, lines 12a–12c; check the applicable exemption application and funder requests | Separate having a policy, requiring disclosure, and operating the process |
| Whistleblower and non-retaliation | Form 990, Part VI, line 13; check applicable law | Give people a reporting route and explain who handles a concern |
| Document retention and destruction | Form 990, Part VI, line 14; check recordkeeping duties | Assign responsibility for preserving and disposing of records |
| Gift acceptance | Schedule M, line 31, for organizations required to file it | Define review of nonstandard contributions before accepting them |
| Board member role and commitment | Your governing documents and any relevant funding conditions | Make responsibilities and expectations clear |
| Volunteer screening, conduct and safeguarding | Your programs, applicable law, and insurance conditions | Choose screening and supervision appropriate to the work |
| Confidentiality and privacy | The information you hold and the rules that apply to it | Specify access, storage, and an incident-reporting route |
The first three rows refer to the Form 990 policy questions (opens in new tab). Schedule M and its instructions (opens in new tab) apply when Form 990, Part IV, line 29 or 30 is answered Yes; receiving any noncash gift does not by itself mean every nonprofit must file that schedule.
Four policies to evaluate first
For a small organization building its policy register, these are useful starting points. Change the order if your activities create a more urgent need:
- Conflict of interest, with a disclosure process. The IRS provides a sample in Appendix A of the Form 1023 instructions (opens in new tab). Adapt it to your organization rather than treating it as a completed policy.
- Whistleblower and non-retaliation. Provide an alternate reporting route when a concern involves the person who normally receives reports.
- Document retention and destruction. Have the retention schedule and legal-hold procedure reviewed. Do not delete records simply because a calendar reminder fires; applicable duties and holds can require preservation.
- Gift acceptance. Decide who can accept routine gifts and who reviews unusual assets or restrictions, including conditions attached to cash.
These choices need implementation as well as approval. A meeting does not guarantee that every reporting answer changes. For Form 990 policy questions, check what was adopted by the end of the tax year; adopting a policy before filing does not retroactively establish it for the prior year. IRS timing guidance (opens in new tab)
The three questions inside a conflict of interest policy
Form 990, Part VI asks separately about a written policy (12a), an annual disclosure requirement for officers, directors, trustees, and key employees (12b), and regular monitoring and enforcement (12c). Follow the form’s skip instructions and answer each applicable line on its own facts. A Yes to 12c also calls for a Schedule O explanation. There is no combined two-out-of-three score. IRS Form 990 instructions (opens in new tab)
As a working practice, track disclosures from everyone covered by your policy, including people reporting no interests. Have someone review the responses, follow up on missing information, and retain the records of how a declared conflict was handled. Requiring a form and actually operating that process are different things.
Fill in the decisions and get the draft reviewed
Name who receives a report, who reviews a gift, who owns the records, and who follows up on disclosures. Have retention periods and approval thresholds checked against applicable requirements instead of filling every blank by preference. Ask a nonprofit lawyer about legal questions and an accountant about reporting and recordkeeping; agree on the scope and fee first. Preparing a draft does not guarantee that review is cheaper than a replacement.
Record an authorized adoption decision
A filled-in policy is a draft until an authorized decision adopts it. For Form 990 reporting, Section B recognizes adoption by the governing body or an authorized committee. Use the procedure allowed by applicable law and your governing documents, which may permit a meeting or written consent. IRS adoption guidance (opens in new tab)
Five steps:
- Circulate it with the agenda, several days ahead, so directors can actually read it.
- Put it on the agenda marked Decide, not Discuss.
- Move it in words that will still make sense in five years: “That the board adopt the Conflict of Interest Policy in the form circulated with the agenda, effective today.”
- Record the decision, effective date, vote, and any recusals in the minutes; include a mover and seconder if your procedure uses them. If an authorized written consent is used instead, preserve it with the policy.
- Add the adoption and effective dates, approving body, decision-record link, owner, and next review date to your register. Use a motion number if helpful.
Schedule disclosures for the people covered by your policy and review retention responsibilities. An annual retention review need not involve destroying anything. Check applicable periods and legal holds first, and assign an owner to follow up on missing disclosures and unresolved issues.
When to get professional help early
For the following work, ask a qualified adviser about the appropriate process before relying on a generic draft. This is a risk-based recommendation, not a claim that templates are legally forbidden:
- Articles of incorporation and bylaws. They are your organization’s constitution, they are measured against state law, and a defect is expensive to unwind.
- The exemption application. Use the applicable IRS form and instructions; get help with eligibility or legal questions.
- Employment contracts, personnel handbooks, and terminating an employee. Employment law is state-specific and unforgiving.
- Fiscal sponsorship, joint ventures, and lobbying or political activity. Have an adviser assess the rules for your organization’s tax status and plans.
- Anything specific to a licensed program — childcare, health, housing, education, food service — where your license sets rules that override any general template.
Where to start today
Before adopting anything, spend twenty minutes filling in a one-page register of what you already have: each policy, when the board adopted it, when it was last reviewed, and where it is filed. That exercise is what shows you the real gaps. Keep the determination letter and approval records in a shared location with appropriate access, rather than relying on one person’s inbox.
The free board meeting agenda and minutes templates are ungated and give you the two documents this whole process runs through: an agenda with a decide-or-discuss column, and minutes in the motion-and-vote format that makes an adoption vote provable. The Nonprofit Board & Volunteer Policy Template Pack adds the sixteen documents themselves, a printable map from each governance question to the document that answers it, and a guide that gives every document its own page. That pack also ships inside the Nonprofit & Congregation Operations Kit, which sets it beside the grant, giving and volunteer files a board is asked about in the same meeting.
For the vocabulary, see what a conflict of interest policy is and what a gift acceptance policy is. Weighing the build-or-hire question? See policy templates vs hiring a nonprofit lawyer.
This is general information about how small nonprofits organize their governance paperwork, not legal, tax, or compliance advice. Requirements differ by state and change over time. Governing documents must themselves comply with applicable law. Have a lawyer who knows nonprofit law in your state resolve legal questions before you adopt a policy.
