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Nonprofit Policies Required Template

Six documents and three sheets that track whether each required policy is current, not just adopted, and whether it was applied when it mattered.

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Pack of 9 files: 6 documents, 3 spreadsheets

Nonprofit Policies Required Template
  • How the 990 Answer-key Register WorksDocument
  • Conflict of Interest PolicyDocument
  • Whistleblower PolicyDocument
  • Document Retention and Destruction PolicyDocument
  • Gift Acceptance PolicyDocument
  • Adoption NoteDocument
  • Policy RegisterSpreadsheet
  • Annual Disclosure TrackerSpreadsheet
  • Review CalendarSpreadsheet

Search 'nonprofit policies required' and every result names the same four policies: conflict of interest, whistleblower, document retention and destruction, and gift acceptance. Adopt all four, and Form 990 Part VI lines 12a, 13 and 14 all read Yes, because each line asks only whether a policy exists as of the end of the tax year. None of them ask whether the board has looked at it since, and Schedule M line 31 asks only whether a gift acceptance policy exists, never whether it was applied to the gift that actually needed it.

This pack prices the population Line 12b actually names. A key employee is not a title, it is three tests run against real pay: the $150,000 Test, the Responsibility Test, and the Top 20 Test, all three required. In the worked example, a raise takes the Director of Community Health Screenings' reportable compensation to $152,400, and her programme's $273,200 full cost is 13.76% of the organization's $1,984,800 in total expenses, clearing the Responsibility Test's 10% threshold. That happens fourteen days before the board's disclosure round, which uses the prior list and never asks her.

As of 1 May 2026, she has gone 106 days undisclosed, and the gap would run 365 days between rounds if nothing caught it. The Gift Acceptance Policy has fared worse: never reviewed in the 6.6 years since it was adopted. Nine days earlier, a one-third interest in a residential duplex, appraised at $61,000, arrived, meeting the Schedule M instructions' own test for a nonstandard contribution, no ready market and a value needing an appraisal. No review has been opened, though the policy answers Schedule M line 31 Yes regardless.

What "the policy exists" and "the policy is current" look like as two different columns

The Policy Register's two dates, the Annual Disclosure Tracker's three-part test, and the Review Calendar sorted by days overdue.

Nonprofit Policies Required Template
RiverPolicy Register

Policy Register

Illustrative, for a fictional community health nonprofit called Cedar Line Community Health. Fiscal year ending 30 June 2026, register run 1 May 2026, two weeks ahead of the 14 May board meeting.

PolicyAnswersAdoptedReviewedCycleDays overdue
Conflict of InterestPart VI, 12a & 12b12 Sep 201915 Jan 20261 year0
WhistleblowerPart VI, 1312 Sep 201918 Jan 20222 years834
Document Retention and DestructionPart VI, 1412 Sep 201918 Jan 20222 years834
Gift AcceptanceSchedule M, 3112 Sep 2019never3 years1,327
4 policiesanswer every line Yes2 at 834, 1 at 1,327

Every one of these four rows answers its Form 990 or Schedule M line Yes, honestly, because the line only asks whether the policy exists as of year end. The right column is the fact the return never sees: two policies are 834 days past the review the board itself scheduled, and Gift Acceptance has never been reviewed since the day it was adopted, 1,327 days ago.

RiverAnnual Disclosure Tracker

Annual Disclosure Tracker

Line 12b's population, scored against real pay rather than a title or a carried-forward list. Disclosure round run 15 Jan 2026.

Covered personCompensation$150k TestResp. TestTop 20Key employeeDays undisclosed
Executive Directorofficern/an/an/aalways covered0
9 sitting directorsdirectorsn/an/an/aalways covered0, 9 of 9 signed
Dir. of Community Health Screenings$152,400Pass13.76%, passPassYes, 1 Jan 2026106
Dir. of Nutrition Counseling$118,000Fail19.22%, passPassNon/a
Dir. of Development$96,800Fail6.55%, failnot reachedNon/a
13 covered1 undisclosed106 days

Two directors fail on two different tests, which is the point of running all three rather than one: passing the Responsibility Test alone, at 19.22% or even higher, proves nothing without the $150,000 Test beside it. The Community Health Screenings director passes all three, and her raise took effect fourteen days before the round that should have asked her.

RiverReview Calendar

Review Calendar

Sorted by days overdue, most overdue first, with the live trigger since the last review carried separately from the calendar date.

PolicyLast reviewedNext dueDays overdueLive trigger since
Gift Acceptancenever since adoption12 Sep 20221,3271 gift, $61,000, 22 Apr 2026. No review opened
Whistleblower18 Jan 202218 Jan 2024834none recorded
Document Retention and Destruction18 Jan 202218 Jan 20248342 grant types added, never checked
Conflict of Interest15 Jan 202615 Jan 202701 new key employee since this review

Current by date and still missing a fact is what the bottom row shows: the conflict of interest review closed with nothing overdue and one new key employee undisclosed anyway. Overdue by date and untested against the one gift that mattered is the top row, and it is the larger gap of the two.

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What is in the pack

01

Policy Register with two dates

Adoption date and last-reviewed date against the board's own cycle, so a policy 834 days past review and one reviewed last month stop reading as the same Yes.

02

Annual Disclosure Tracker

Runs the $150,000 Test, the Responsibility Test and the Top 20 Test against real pay, not job titles, and flags anyone who crossed the line since the last round.

03

Review Calendar, sorted by days overdue

Carries a live trigger separately from the calendar date, the way a lapsed volunteer credential is a trigger a renewal date alone would miss.

04

Four required policies, each naming its line

Conflict of interest, whistleblower, document retention and destruction, and gift acceptance, each stating the exact Form 990 or Schedule M line it answers.

05

Adoption Note for the board

One narrative a director reads once, naming the specific gap and the date it opened rather than making them cross-reference three sheets.

06

Built to feed the board packet

The same overdue review a board packet's reserved matters register can only flag as a date, with the reason behind it attached.

How it works

  1. 1

    Send your current policies

    Whatever exists today, or a plain statement that a policy has never been adopted, so the register starts from what is actually true rather than a template default.

  2. 2

    Send the minutes and the roster

    Board minutes covering each policy's adoption and its most recent review, plus the staff roster with actual compensation, including any raise or stipend that took effect during the year.

  3. 3

    Run the three tests, then the gift check

    The $150,000 Test, the Responsibility Test and the Top 20 Test against real pay, then the gift log since the last review, checked against the gift acceptance policy's own procedure.

  4. 4

    Get a register, not a rewrite

    The four documents change only where the register finds a real gap. Everything else is dated evidence a board member or the 990 organizer can act on directly.

Frequently asked questions

Isn't adopting all four policies enough to answer these Form 990 lines?

Yes, for lines 12a, 13 and 14 alone. Each one asks only whether the organization had the policy as of the end of its tax year, and an adopted-once, never-reviewed policy answers that honestly. Line 12b and Schedule M line 31 ask more: who actually discloses, and whether the policy was applied. Adoption alone cannot answer either.

Who actually counts as a key employee under line 12b?

Not a title. Form 990 defines it as three tests, applied in order, to real compensation: the $150,000 Test, the Responsibility Test, and the Top 20 Test, all three required. The Responsibility Test runs off the organization's own total expenses, 10% or more of activities, assets, income, or expenses, so it is a computed threshold, not a guess based on how senior a role sounds.

Can a role pass the Responsibility Test and still not be a key employee?

Yes, and the worked example shows both directions. A program director whose segment is 19.22% of total expenses clears the Responsibility Test easily, but her compensation is under $150,000, so she fails the first test and is not a key employee. All three tests are required together; passing two is not enough.

Can we just backdate the disclosure to make the round look complete?

No, and the pack will not draft one. A late disclosure, honestly dated the day it is actually signed, is a real record of a gap that got closed. One dated to look like it happened on schedule when it did not is a different problem. State the gap, close it now, and let the real date stand.

What exactly counts as a nonstandard contribution under the gift acceptance policy?

The Schedule M instructions define it precisely: an item not reasonably expected to further the organization's exempt purposes, with no ready market to convert it to cash, and a value that is highly speculative or difficult to ascertain. A fractional interest in real property, like the duplex share in the worked example, is the textbook case, because both conditions apply at once.

How does this connect to the board packet and the 990 organizer?

The board's own Reserved Matters Register already carries the whistleblower and retention review as overdue since 2022; this pack is the deeper cut behind that one row. The 990 organizer draws the same $1,984,800 in total expenses this pack uses to compute the Responsibility Test's 10% threshold, so the two never disagree on the number.

Who decides whether a specific transaction is actually a conflict?

This pack does not. The conflict of interest policy sets the procedure: the interested person discloses and does not vote, the remaining members decide without them present, and the reasoning is minuted the day it happens. What this pack adds is catching the person who was never asked, because their compensation crossed a threshold after the standing list was fixed.

Sources

  1. IRSInstructions for Form 990 Return of Organization Exempt From Income Tax (2025) (opens in a new tab)
  2. IRS2025 Schedule M (Form 990) (opens in a new tab)

Written by

Chandler Supple

Co-founder & CEO, River

Chandler has spent the last six years working in AI, building tools for millions of users and Fortune 100 companies. In 2025, he co-founded River to build a new kind of operating system for AI agents.

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Reviewed by

Brian Joseff, Co-founder, River

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Related

Nonprofit board meeting pack

Where the whistleblower and retention review already reads as overdue since 2022. This pack is the deeper register behind that one line.

Form 990 preparation pack

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Volunteer management pack

The same dated-credential logic applied to a background check instead of a policy review: a lapse is a fact, not a rounding error.

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Find out which of your policies are actually current

Send your current policies, the board minutes behind them, and your staff roster. The first thing back is which reviews are overdue and who the disclosure round missed.

Score my policies