Imagine a private foundation wires a $50,000 grant to a nonprofit, only to discover the organization quietly lost its 501(C)(3) status two years earlier for failing to file its Form 990. That grant is now a taxable expenditure, potentially triggering excise tax penalties and an IRS audit. The tool that prevents this scenario is the IRS Tax Exempt Organization Search (TEOS), the modern, live successor to the once-bulky paper document known as Publication 78.
This guide walks donors, grantmakers, and nonprofit professionals through exactly how to use Publication 78 data: what it tells you, what it doesn’t, and how to build a repeatable due diligence workflow around it, including how Crowded can streamline that process at scale.
TL;DR
- Publication 78 is the IRS’s live, monthly-updated database confirming which nonprofits can legally receive tax-deductible contributions, and it’s the only source private foundations can rely on under Revenue Procedure 2011-33.
- A 501(C)(3) determination letter is not enough: roughly 1 in 3 registered U.S. nonprofits have lost tax-exempt status at some point, and an old letter won’t tell you that.
- Searching TEOS takes minutes, but the step most grantmakers skip, timestamped documentation, is exactly what the IRS looks for in an audit.
- Pub 78 only covers deductibility; a complete due diligence workflow also requires an Auto-Revocation List check, Form 990 review, and OFAC screening before any funds move.
- For foundations and DAF sponsors processing grants at volume, manual lookups are a liability. Crowded embeds verification, documentation, and revocation alerts directly into the disbursement workflow.
What Is Publication 78?
Publication 78 is the IRS list of organizations eligible to receive tax-deductible charitable contributions, now maintained online through the Tax Exempt Organization Search (TEOS). It was originally a printed, multi-volume list updated quarterly. Still, the IRS moved it online in 2011 and rebranded the platform as TEOS in 2018, expanding its features and renaming the dataset “Pub. 78 Data.”
Today, when compliance professionals, grantmakers, or donors say “Publication 78” or “check Pub 78,” they mean the live, searchable dataset hosted at apps.irs.gov/app/eos/.
What Is Publication 78 Data, And What Does It Actually Tell You?
Publication 78 Data is the IRS dataset confirming which organizations are eligible to receive tax-deductible contributions under Section 170. In TEOS, users can verify a nonprofit’s deductibility status and view key details, including its legal name, EIN, location, deductibility code, and foundation classification.
What does “On Publication 78 Data List: YES” mean?
It means the organization has an active IRS determination that its contributions are tax-deductible under Section 170. For donors and grantmakers, that is the key confirmation. Pub. 78 Data does not include DBA names; it lists only the legal name on file with the IRS, and some eligible donees may not appear even if donations to them are deductible. The dataset is updated monthly, usually on the second Tuesday.
Publication 78 vs. 501(C)(3)
This is a key distinction in nonprofit compliance. 501(C)(3) status is the legal classification the IRS grants, while inclusion in Pub. 78 Data confirms that the status is still active and that contributions remain tax-deductible. That matters because an organization can lose its exempt status after failing to file required Form 990-series returns for three consecutive years and still hold an old determination letter that no longer reflects its current standing.
For grantmakers, a determination letter alone is not enough. Revenue Procedure 2011-33 allows private foundations to rely on Pub. 78 Data and related IRS databases to confirm whether a grantee’s exempt status is still valid, unless they know otherwise. That is why real-time verification matters: as of April 2025, about 1.13 million of 3.05 million registered organizations had lost tax-exempt status at some point.
How to Search Publication 78 Data?
Searching TEOS is straightforward once you know the right approach. Here is a reliable workflow:
- Navigate to the TEOS portal at apps.irs.gov/app/eos/.
- Select “Publication 78 Data” as your search type from the dropdown menu.
- Search by EIN whenever possible — this is the most reliable method and eliminates ambiguity caused by name matching. If you don’t have the EIN, use quotation marks to search by the organization’s full legal name and avoid common words like “the” or “foundation.” If you are not getting the results you want, try sorting by city, state, or zip code.
- Review the deductibility code and foundation classification in the result. Note whether the organization is classified as a Type I, Type II, or Type III supporting organization, or as a public charity; this matters for private foundations evaluating expenditure responsibility requirements.
- Cross-reference the Auto-Revocation List in the same TEOS session. If you find an organization on the Auto-Revocation List, it may have been reinstated by the IRS since the automatic revocation date. Search Pub. 78 Data to confirm whether reinstatement has occurred.
- Screenshot or export the result with a timestamp. This timestamped record is your audit trail. Without documentation, your due diligence never happened in the eyes of the IRS.
What Pub 78 Doesn’t Tell You, And What Else You Need
Pub. 78 Data is necessary, but it is not complete due diligence. It does not capture every revoked organization, especially those that lost exempt status through an IRS examination rather than auto-revocation. It also says nothing about financial health, governance, mission fit, or grant compliance. For a fuller review, it should be paired with the organization’s latest Form 990, the EO Business Master File Extract, an OFAC/SDN check, and, for larger gifts, the determination letter.
TEOS lets users view recently filed Form 990s and determination letters issued since January 1, 2014. If a determination letter is not available online, it can be requested through Form 4506-A or 4506-B. For grantmakers, extra care is still required: foundations and donor-advised fund sponsors must confirm whether a public charity is, in fact, a supporting organization under Section 509(a)(3), as that can trigger expenditure responsibility rules. Revenue Procedure 2011-33 offers a safe harbor, but not if the IRS has already publicly reported a status change or the grantor already knew about it.
How Often Is Publication 78 Updated?
The Publication 78 dataset is updated monthly, usually on the second Tuesday. That makes it far more current than the old paper version, but verification is still only valid at the time of the transaction. For multi-year grants, organizations should re-check status before each disbursement. The IRS also provides bulk download files, enabling automated verification at scale.
Building a Pub 78 Verification Workflow That Holds Up to IRS Scrutiny
Manual TEOS lookups work for one-off checks, but they do not hold up at scale. Foundations and DAF sponsors handling larger grant volumes need a repeatable process. Best practice is to document each review by confirming eligibility through Pub. 78 Data or TEOS and checking the auto-revocation list and related IRS records before disbursing funds.
A compliant grant workflow should include a Pub. 78 check, an Auto-Revocation List review, Form 990 review, grant agreement, and re-verification before each disbursement. Every step should be documented, timestamped, and easily retrievable during an audit. Crowded helps by embedding that verification into the workflow, linking each check to the transaction record, preserving audit-ready timestamps, and flagging revocation issues before funds go out.
The Bottom Line
Publication 78 is no longer a dusty government pamphlet. It is a live, monthly-updated dataset that every donor, foundation, and nonprofit should know how to use before any charitable transaction changes hands.
Checking Pub 78 Data before a donation or grant disbursement isn’t just best practice; for private foundations, relying on it is the IRS-sanctioned safe harbor under Revenue Procedure 2011-33. But it is only one layer. Pair it with the Auto-Revocation List, the relevant Form 990, an OFAC check, and a timestamped documentation record, and you have a due diligence process that holds up to scrutiny.
Crowded automates this entire process.
Frequently Asked Questions
Can I use a nonprofit’s determination letter instead of checking Pub. 78 Data?
No. A determination letter shows that an organization was granted 501(C)(3) status at some point, but it does not confirm that the status is still active. Pub. 78 Data reflects current standing, which is why it is the safer source for real-time verification.
What happens if I disburse a grant and the recipient later turns out to have been revoked?
Do churches and government agencies appear in Publication 78 Data?
Not always. Some eligible donees, including churches, government units, and certain group exemption subordinates, may not appear even though contributions to them are still deductible. Absence from TEOS does not automatically mean the organization is ineligible.
How do donor-advised funds fit into Publication 78 compliance?
DAF sponsors, such as private foundations, must verify grantee eligibility before disbursing funds. If a DAF sends money to a revoked organization, the sponsor carries the compliance risk. Crowded supports that workflow by building verification into the approval process.
Is one Pub. 78 check enough for a multi-year grant?
No. A Pub. 78 check is valid only at the time of the transaction. For multi-year grants, best practice is to re-verify before each disbursement. Crowded makes that ongoing review easier by turning it into a repeatable workflow step.
What is the OFAC/SDN check, and why does it matter alongside Pub. 78?
Pub. 78 confirms tax-deductible status, but it does not screen for sanctions risk. An organization can appear in Pub. 78 Data and still be on the OFAC SDN list. A complete due diligence process should cover both, and Crowded helps bring those checks into one workflow.
