When it comes to year-end donations, the biggest factor is “When does the donor give up control of the gift?” This is where the postmark rule comes into play. When a donor puts a donation in the mailbox, it is no longer under their control. The most reliable way to determine when the donation was dropped in the mailbox would be to look at the postmark date. In short, the postmark date (or the equivalent) determines when the donation should be recorded.
An assumption I’m making is that your accounting policies on when to record income are mirroring the IRS rules. This just makes it easier to have one set of rules for accounting and tax statements for charitable contributions. Here’s a table that might help keep the postmark rule straight as it pertains to other ways to give.
| Giving Scenario | Month |
| Check dated December and postmarked December | December |
| Check dated December and postmarked January | January |
| Check dated January and postmarked December | January as this is a post-dated check |
| Bill Pay check dated December but no postmark and received in January | December as bank withdrew money from donor’s account on check date |
| Online gift submitted in December with funds received in January | December |
| Online gift submitted in January with funds received in January | January |
| Check dated December but dropped off at the church office in January | January |
| Check dated in January but dropped in the December offering plate | January as this is a post-dated check |
Useful Links
- IRS Guidance: https://www.irs.gov/pub/irs-news/IR-13-098.pdf
Hi Jeff, I wanted to point out another possibility that I have seen more and more since COVID – donors who use online bill pay through their bank and the bank sends a check (or groups of checks in one envelope) and the envelope does NOT have a postmark because I guess it was bulk mail. I have used the date on the checks in this case due to that seems to be the date the donor initiated the payment and so relinquished control on that date. Does that sound right?
Thank you for this! Yes, I would go by the check date in that case for the online bill pay. I’m seeing around 10% of checks coming through via pill pay, but, until you mentioned it, I never noticed the lack of a postmark. I’ll update my post.