How to File a Form 1023 Expedited Handling Request

Organizations seeking tax-exempt status under Internal Revenue Code Section 501(c)(3) must file Form 1023. The Internal Revenue Service (IRS) processes these applications in the order they are received, which can involve a substantial waiting period. For organizations in specific, urgent situations, the IRS provides a procedure to request a review ahead of the standard queue. This process is known as an expedited handling request.

The IRS grants these requests at its discretion for a narrow set of compelling reasons. An approval for expedited handling does not ensure the Form 1023 application will be approved; it only means the IRS will review the case sooner. The burden of proof is on the applicant to demonstrate that its circumstances align with IRS criteria. For applications filed in 2025, the relevant guidance is Revenue Procedure 2025-5.

Criteria for Requesting Expedited Handling

The IRS outlines a limited set of circumstances that may justify processing a Form 1023 application ahead of others. These situations are considered compelling because a delay in receiving tax-exempt status would cause an adverse impact on the organization or the public it serves. An organization must clearly demonstrate how its situation fits one of the established criteria to have its request considered.

A Pending Grant

A primary reason the IRS may grant an expedited review is a pending grant from a private foundation or government entity that is contingent on the organization securing 501(c)(3) status. The grant’s award must be conditioned on the applicant receiving a determination letter by a specific date, after which the funds would be forfeited. The organization must show that failing to secure this grant would jeopardize its ability to continue its operations.

To meet this standard, the pending grant must be significant to the organization’s finances. For example, if a new charity with a first-year budget of $100,000 has a $50,000 grant contingent on obtaining 501(c)(3) status by a certain date, the IRS may approve the request. The grant must represent a substantial portion of the organization’s funding, and its loss would severely impact its programs. A general need for funding to receive future, unspecified grants is not a sufficient reason.

A Newly Created Organization Providing Disaster Relief

Another criterion applies to newly created organizations formed to provide disaster relief. This is for situations where there is an urgent need for charitable services in response to a declared emergency, like a hurricane or wildfire. The organization must demonstrate it was established to provide direct relief to victims in an affected area.

An existing organization that adds disaster relief to its programs would not qualify under this provision. The IRS reserves this for entities formed in direct response to a large-scale crisis where a delay in tax-exempt status would hinder the flow of aid to those in need.

IRS Error

An organization may qualify for expedited handling if it can demonstrate that an IRS error has caused an unusual delay in processing its Form 1023 application. This applies to procedural mistakes made by the agency, such as misplacing a file or other administrative errors that have pushed an application beyond normal processing times. The organization must be able to document the error and the resulting delay.

Urgent Issues for U.S. Interests

A final criterion involves situations where a delay in processing would adversely affect U.S. interests. These requests are initiated by other U.S. government officials or agencies who can attest to the organization’s importance to a national program. This category is reserved for unique circumstances with national implications.

Information and Documentation for the Request

To request an expedited review, an organization must prepare a written statement and gather specific supporting evidence. The applicant must provide a complete package that demonstrates its eligibility under one of the IRS criteria.

The written request must state “Expedited Handling Request” at the top of the first page. It must contain the organization’s legal name, its Employer Identification Number (EIN), and the date the Form 1023 was submitted. The statement needs to provide a detailed narrative explaining the compelling reason for the request, referencing the specific IRS criterion it meets. The letter must be signed by a principal officer or an authorized representative.

The required supporting documentation varies depending on the criterion cited. Each piece of documentation should directly substantiate the facts presented in the request letter.

For a request based on a pending grant, a letter from the grantor is required. This letter must be on the granting organization’s letterhead and include the name of the entity giving the grant, the dollar amount, and the date by which 501(c)(3) status must be secured. The letter must also state that the grant will be forfeited if the deadline is not met and describe the impact this loss would have on the applicant’s operations.

If the request is based on disaster relief, documentation should illustrate the disaster and the organization’s role in the response. This can include news articles, official emergency declarations, and descriptions of the organization’s relief activities. Evidence should also show the organization was newly formed to address the disaster, such as articles of incorporation dated shortly after the event.

How to Submit the Expedited Handling Request

The submission method for an expedited handling request depends on whether the Form 1023 is being filed or is already pending. All Form 1023 applications must be filed electronically through the Pay.gov portal, where the expedited review process is integrated. Organizations filing Form 1023-EZ are not eligible to request expedited handling.

When submitting the initial Form 1023, a question on the electronic form allows an applicant to indicate it is requesting expedited handling. The applicant must upload the written request and all supporting documentation as a single PDF file. The IRS recommends a clear filename for this attachment, such as “Expedite Request.”

If an organization seeks expedited review after its Form 1023 has been filed, the request must be submitted electronically. The written request and all supporting documents should be uploaded as a single PDF file to the case through the Pay.gov portal where the original application was filed.

After the request is submitted, the IRS will review the information and notify the organization of its decision. If the request is approved, the Form 1023 application is moved ahead in the processing queue. If denied, the application is not negatively affected and remains in its original place to be processed in standard order.