Starting a Church & 501(c)(3)

The 6 Documents Every New Church Needs in Its First 90 Days

Published 2026-09-09 · Starting a Church & 501(c)(3)

Short answer: six documents. Articles of incorporation filed with the state, bylaws adopted by the board, organizational minutes from the first meeting, the EIN confirmation letter, an adopted conflict-of-interest policy, and a written financial controls and receipting procedure. Get them in that order, since each one depends on the one before it, and keep the signed originals together in one place.

You're meeting in a school cafeteria. Forty people came last Sunday. Somebody has offered to give a thousand dollars and wants to know whether it's deductible, the school is asking for a certificate of insurance, and you can't open a bank account because the bank wants documents you don't have.

Nobody warned you that planting a church involves this much paperwork. Good news: the list of new church documents that actually matter is finite. Six of them, ninety days, done in order, and most of the ongoing panic goes away. The long-form version of the whole process is how to start a church legally, in order. This post is the six pieces of paper.

Why does this need to happen in the first 90 days?

Because everything else waits on it. You can't open a bank account without an EIN and usually a resolution. You can't sign a lease safely as an unincorporated group. You can't issue a proper contribution receipt without an entity. And the money is already arriving.

There's also a personal-risk reason. Until the church is a corporation, the people leading it may be personally exposed for the group's obligations: the lease, the debt, the injury in the parking lot. That's the argument for moving early rather than waiting until things "settle down." We cover the specifics in do you have to incorporate a church.

1. Articles of incorporation

What it is. The short document you file with your state to create the corporation. Usually two to four pages.

What it must contain. The church's exact name, a registered agent and address, the incorporators or initial directors, a purpose clause stating the religious purpose, and a dissolution clause saying where the assets go if the church closes.

Why the two clauses matter. The purpose and dissolution clauses are part of the organizational requirements for federal exempt status (IRS, Exemption requirements for 501(c)(3) organizations). Getting them wrong now means amending later, which costs a filing fee and a board meeting. Check the current instructions for IRS Form 1023 and IRS Publication 1828 against your draft, and if anything is unclear, this is a good hour of a lawyer's time.

Common mistake. Choosing a name nobody checked. Search your state's business registry and do a basic trademark check before you file, not after you print the signs.

2. Bylaws

What it is. The church's internal rulebook: who decides what, and by what process. Not filed with the state; kept in your records.

What it covers. Membership, meetings, notice, quorum, the board, officers, committees, pastoral staff, conflicts, records and amendment. The full breakdown is in the twelve sections church bylaws should have.

The rule for a new church: write bylaws you can actually comply with at your current size. A plant of forty people shouldn't adopt a structure requiring a twelve-member board, quarterly members' meetings and a nominating committee. You'll be out of compliance with your own document by autumn. Start simple; amend as you grow.

3. Organizational minutes

What it is. The written record of your first official board meeting, the meeting where the church becomes operational rather than theoretical.

What that meeting does. Notes that the articles were filed, adopts the bylaws, elects officers, adopts the conflict-of-interest policy, sets the fiscal year, authorizes the bank account and names signers, and authorizes the EIN application. Each of those is a motion, and each motion needs to be in the record.

Why it matters more than it looks. This is the document the bank asks for, the document that proves the bylaws were actually adopted, and the document that shows who has authority to sign for the church. Without it, you have a corporation with no evidence of who runs it. The agenda and the wording are covered in your church's first board meeting.

4. The EIN confirmation letter

What it is. Your federal Employer Identification Number, and the confirmation letter the IRS issues. You apply on Form SS-4 or through the IRS online application (IRS, About Form SS-4).

Why it is on this list. It isn't something you draft, but it's a document you must keep. Banks want it. Payroll needs it. Vendors ask for it. Losing it is a genuine inconvenience.

Note. You need an EIN even if the church will never have an employee. It identifies the entity, not the payroll.

5. The conflict-of-interest policy

What it is. The written procedure the board follows when a decision could benefit someone in the room: disclose, step out, compare, decide, record.

Why in the first ninety days. Because a new church is exactly where this comes up first. The founding pastor's spouse is doing the bookkeeping. A board member's company is doing the build-out. Somebody is renting the church their sound equipment. None of that is wrong; all of it needs a process.

It's also the policy most likely to be asked about if you apply for a determination letter, and it takes one meeting to adopt. See the conflict-of-interest policy every church board needs.

6. Financial controls and a receipting procedure

What it is. A short written procedure covering two things: how money is handled, and how donors are acknowledged.

Handling. Two unrelated people count. Deposits are made promptly. The person who reconciles the bank statement isn't the person who writes the checks. Spending above a set amount needs board approval. In a small church you won't achieve perfect separation of duties, so write down what you can actually do, and have someone independent review the reconciliation monthly.

Receipting. Contribution acknowledgements need specific content and specific timing, and the requirements are set by federal rules rather than by preference (IRS Publication 1771, Charitable Contributions). Get the standard language right once and reuse it. Donors will ask in January, and a receipt that's missing a required element is a problem for them, not just for you.

Why now. Because money is already coming in. Controls adopted before there's anything to control are uncontroversial. Controls introduced after someone has been handling cash alone for two years feel like an accusation.

What about 501(c)(3)?

The honest answer is that this is a real decision, not a formality.

Churches occupy a distinctive position in federal tax law. A church that meets the requirements is generally treated as exempt without being required to apply, and qualifying churches are generally not required to file the annual information return that most exempt organizations file (IRS Publication 1828, Tax Guide for Churches). Many churches still apply for a determination letter anyway, because banks, landlords, grantmakers, state agencies and some donors ask to see one.

What that means practically: applying is often useful, and it isn't automatically urgent in your first ninety days. What is urgent is that your articles contain the right purpose and dissolution language, because that's what an application will be judged against later. Confirm the current requirements against Publication 1828 and the Form 1023 instructions (IRS, About Form 1023), and get counsel before you file if anything about your structure is unusual: multiple campuses, a school, a related nonprofit, or foreign operations.

A 90-day sequence

Weeks 1 to 2. Choose and clear the name. Draft the articles. Identify your initial directors. File with the state.

Weeks 3 to 4. Apply for the EIN once the entity exists. Draft the bylaws and circulate them to the initial directors.

Weeks 5 to 6. Hold the organizational meeting. Adopt bylaws, elect officers, adopt the conflict-of-interest policy, set the fiscal year, authorize the bank account. Write the minutes within three days.

Weeks 7 to 8. Open the bank account with the minutes and the EIN letter. Set up the counting procedure before the next offering. Get the insurance conversation started: general liability at minimum, and ask about directors and officers cover.

Weeks 9 to 12. Adopt the financial controls and receipting procedure. Build the corporate records book so that articles, EIN letter, bylaws, minutes, policies and insurance all sit in one place. The rest of the church startup documents can be added to it as you go. Decide as a board whether you're applying for a determination letter, and record the decision either way.

If you have children in the building, move a child safety policy up into this window regardless of what else slips. It's the one exposure where "we'll get to it" has consequences that can't be corrected afterwards.

How new churches get this wrong

Operating for two years before incorporating. The most common, and the one with real personal exposure attached.

Bylaws copied from a church ten times your size. Unfollowable within months.

No minutes from the first meeting. The bank asks, and there's nothing to hand over.

The pastor's personal bank account. It happens, always innocently, and it's very hard to unwind cleanly. Separate accounts from day one.

Receipts that say "thank you for your generous gift" and nothing else. Acknowledgement letters have required content; get the template right once.

Everything in one person's email. Build the records book in month three, not in year five.

Common questions

Do we need a lawyer to start a church?

Not necessarily for a straightforward single-site church using solid templates. Get counsel if you're buying property, operating a school or daycare, employing staff from the start, structuring multiple entities, or if your state has unusual requirements for religious corporations.

Can we take donations before we incorporate?

People can give you money at any time. Whether it's deductible to them, and who is legally responsible for it, are different questions, and that's the argument for moving quickly.

What if we already did some of this out of order?

That's normal and usually fixable. Ratify the earlier actions at a properly held board meeting, record that you're doing so, and move on. Ratifying openly is far better than a gap someone finds later.

How much of this can we do ourselves?

Most of it, with good templates and a board willing to hold real meetings. The two places to spend money are the articles, if anything about your situation is unusual, and insurance advice.

The practical wrap

Six documents. File the articles, adopt the bylaws, hold the meeting and write it down, get the EIN, adopt the conflict policy, write down how money is handled. Ninety days, in order, and then you can go back to the actual work, knowing the paperwork underneath it will hold.

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Get the whole startup sequence in one place. Start My Church Kit is the full set of documents to legally establish your church: the formation paperwork, bylaws, first-meeting resolutions and the core policies, assembled in the order you actually need them. $149, instant download.

*Faith Docs provides self-help document templates, not legal advice. We are not a law firm. For representation, consult a licensed attorney.*