Does an HOA need an EIN?

By OurHOA · General information · Revised September 23, 2026

Why nearly every HOA needs an EIN, how a volunteer board applies free from the IRS, what to do when nobody can find the number, and when a new one is required.

Part of the HOA board handbook: treasurer and money.

Yes, in nearly every case, and the bank usually forces the issue first

An employer identification number is the federal taxpayer identification number for an entity, the way a Social Security number is for a person. An association is an entity separate from the volunteers who run it, and two ordinary things it has to do require one. The first is the annual federal return, because a return needs a taxpayer identification number on it, and whether the association files Form 1120-H or Form 1120 is a separate question our guide on whether an HOA has to file a tax return works through. The second is the bank account, and this is the one boards hit first. The federal customer identification rules at 31 CFR 1020.220(a)(2)(i)(A) require a bank to obtain an identification number before opening an account, and for a U.S. person that is not an individual, that number is a taxpayer identification number. A bank cannot open an account in the association's name without one. The workaround boards sometimes reach for, running association money through a volunteer's personal account under their Social Security number, is worse than it looks: the interest is reported as that person's income, the balance is that person's asset if they are sued or divorced, and the next treasurer has no way to take the account over.

An EIN is not tax-exempt status, and it does not mean you have employees

The word employer in the name misleads almost every volunteer who applies. An EIN is an identification number, not a payroll registration, and an association with no staff at all still needs one. It is also not a grant of tax-exempt status. Being a nonprofit corporation under your state's nonprofit act is a matter of state law and says nothing about federal income tax, and the Form SS-4 instructions are explicit that an organization seeking tax-exempt status must separately file Form 1023, Form 1023-EZ or Form 1024. Most homeowners associations never file either one. They are taxable corporations that reduce or eliminate the tax by electing to file Form 1120-H under section 528, which treats member assessments as exempt function income. Applying for an EIN does not start that election and does not end it. On the application itself, an association that is incorporated as a nonprofit will normally check the other nonprofit box on line 9a and describe itself as a homeowners association, since the instructions ask you to check other and specify the type when the organization is not a church or church-controlled.

How to apply, and what it should cost

It is free. The IRS issues an EIN at no charge, and any site that quotes a filing fee is charging you to fill in a form you can complete yourself in about fifteen minutes. The fastest route is the online assistant on irs.gov, which issues the number during the session. It is available Monday through Friday from 6:00 a.m. to 1:00 a.m. Eastern the following day, Saturday from 6:00 a.m. to 9:00 p.m., and Sunday from 6:00 p.m. to midnight, and only one EIN is issued per responsible party per day. If nobody on the board can apply online, Form SS-4 by fax generally produces the number within four business days, and by mail in roughly four weeks, so the instructions tell filers to send it four to five weeks before they need it. Gather five things before you start: the association's exact legal name as it appears on the articles filed with your secretary of state, its mailing address, the date it was formed, the month its fiscal year ends, and the reason for applying, which for a new association is often banking purpose. Print or save the confirmation at the end of the online session. It is the only time that page appears, and it is what the bank will ask for.

The responsible party is a person, and it changes when your board does

The application asks for a responsible party, which the Form SS-4 instructions define as the person who ultimately owns or controls the entity or who exercises ultimate effective control over it, and which, unless the applicant is a government entity, must be an individual, that is a natural person, not an entity. For an association that is usually the president or the treasurer, named with their own Social Security number or ITIN. This trips up volunteers who think they are signing up for personal liability for the association's taxes. They are not. It identifies who the IRS talks to, and it is a board role rather than an ownership claim. What matters more is the part boards skip: when that officer leaves, the change has to be reported to the IRS within 60 days on Form 8822-B, which is also the form that changes the association's mailing address. Skip it and IRS notices keep arriving at a volunteer who resigned three years ago, which is how a small association discovers a penalty notice long after the response window closed. Put both the EIN paperwork and the 8822-B on the year-end checklist described in our guide on handing off HOA records to a new board.

When nobody can find the number

This is the common case for an association formed in the 1990s whose records moved garage to garage. Work through the sources in order before calling anyone. The IRS confirmation notice is CP 575, now issued digitally and available through Business Tax Account, and the IRS states that the digital CP 575 is accepted by banks and other institutions as written confirmation of an entity's EIN. The older equivalent a bank may ask for by name is Letter 147C, EIN previously assigned. Failing that, the number appears on any previously filed return, on the account records at the bank where it was used to open the account, and on state or local license applications. If none of that produces it, the IRS Business and Specialty Tax Line at 800-829-4933 will search for it, from 7:00 a.m. to 7:00 p.m. local time Monday through Friday, and the caller has to be someone authorized to receive it, which means an officer of record rather than whichever volunteer is free that afternoon. What not to do is apply for a second EIN because the first one cannot be found. Two numbers for one association means returns filed under one and vendor 1099s issued under the other, and untangling that costs far more than a phone call.

When the association actually needs a new one

Rarely, and the IRS publishes the list. A corporation needs a new EIN if it gets a new charter from the secretary of state, if it merges and creates a new corporation, or if it becomes a subsidiary of another corporation. It does not need one merely for changing its name or its location, for declaring bankruptcy, for surviving a corporate merger, or for reorganizing to change only its identity or location. Two situations make that list matter to a board. The first is reinstatement: if the association was administratively dissolved for missed state filings and the board reacts by forming a brand new corporation rather than reinstating the existing one, that new corporation is a new entity with a new charter, so it needs its own EIN and it does not inherit the old one's filing history. Check your standing with the state before choosing a route, which our guide on checking whether your HOA is in good standing with the state walks through. The second is a merger of two associations. The corporation that survives keeps its own EIN, and the one that disappears files a final return under its number rather than abandoning it quietly, a detail worth settling in the merger agreement rather than the week the return is due.

Sources

These guides are general education for HOA boards and residents, not legal, tax, or financial advice. Rules vary by state and by your community's governing documents - check with a professional for your situation.

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