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Published:   |   Last Updated: May 29, 2026

Expedite Resolution of Centralized Authorization File Number Suspensions to Protect Tax Professionals and Taxpayers

The IRS should expedite resolution of Centralized Authorization File number suspensions to avoid unfairly harming tax professionals and the taxpayers they represent during lengthy fraud investigations.

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Objective 12

TAS Recommends

To mitigate the negative impact of CAF number suspensions on taxpayer representation, TAS recommends
that the IRS:

Recommendation 5-1

Issue Interim CAF Numbers: The IRS should issue interim CAF numbers to practitioners believed to be victims of identity theft. This measure will allow practitioners to continue representing taxpayers during the fraud review process, minimizing disruptions to taxpayer representation.

Quarter 1 Updates

TAS is reviewing how to incorporate this initiative into an existing or new Collaborative Team, a Systemic Advocacy Project, or a potential FY 2025 Annual Report to Congress Most Serious Problem. Progress during this period was affected by the lapse in appropriations and related operational impacts, including reduced staffing capacity, reassignment of work and priorities, and a reevaluation of TAS’s approach to managing systemic advocacy objectives and associated initiatives.

Quarter 2 Updates

TAS determined that the most effective course of action for this Systemic Advocacy Objective (SAO) was to elevate the issue to a Most Serious Problem (MSP) in the FY 2025 Annual Report to Congress. TAS has provided the IRS with the following recommendation to further address this issue, as outlined in MSP Centralized Authorization File, Recommendation:

Study ways to shorten and mitigate CAF “pending review” suspensions. Study and implement ways to shorten the duration of CAF investigations that place CAF numbers in “pending review” status. The IRS should also explore interim measures to minimize disruption to taxpayers and their representatives while reviews are ongoing, particularly when no confirmed compromise exists.

The IRS agreed to enhance publicly available guidance on IRS.gov to better explain the CAF pending review process and to conduct a Lean Six Sigma Opportunity (LSSO) Assessment to identify improvement opportunities in the process.

As a result of elevating this issue from an SAO to an MSP, TAS is closing the SAO and will instead track the IRS’s progress on implementing this recommendation through the Annual Report to Congress (ARC) Recommendations Tracker page.

Recommendation 5-2

Improve Communication: The IRS should enhance communication with affected practitioners and taxpayers. This includes revising its letters to provide clear and timely information about the suspension process and the available options for practitioners.

Quarter 1 Updates

TAS is reviewing how to incorporate this initiative into an existing or new Collaborative Team, a Systemic Advocacy Project, or a potential FY 2025 Annual Report to Congress Most Serious Problem. Progress during this period was affected by the lapse in appropriations and related operational impacts, including reduced staffing capacity, reassignment of work and priorities, and a reevaluation of TAS’s approach to managing systemic advocacy objectives and associated initiatives.

Quarter 2 Updates

TAS determined that the most effective course of action for this Systemic Advocacy Objective (SAO) was to elevate the issue to a Most Serious Problem (MSP) in the FY 2025 Annual Report to Congress. TAS has provided the IRS with the following recommendation to further address this issue, as outlined in MSP Centralized Authorization File, Recommendation:

Study ways to shorten and mitigate CAF “pending review” suspensions. Study and implement ways to shorten the duration of CAF investigations that place CAF numbers in “pending review” status. The IRS should also explore interim measures to minimize disruption to taxpayers and their representatives while reviews are ongoing, particularly when no confirmed compromise exists.

The IRS agreed to enhance publicly available guidance on IRS.gov to better explain the CAF pending review process and to conduct a Lean Six Sigma Opportunity (LSSO) Assessment to identify improvement opportunities in the process.

As a result of elevating this issue from an SAO to an MSP, TAS is closing the SAO and will instead track the IRS’s progress on implementing this recommendation through the Annual Report to Congress (ARC) Recommendations Tracker page.

Recommendation 5-3

Review Policy: The IRS should conduct a comprehensive policy review to explore less disruptive alternatives for preventing fraud while safeguarding taxpayers’ right to the representation of their choice. This review should include input from key stakeholders, including representatives, practitioners, and taxpayer advocacy groups.

 

Quarter 1 Updates

TAS is reviewing how to incorporate this initiative into an existing or new Collaborative Team, a Systemic Advocacy Project, or a potential FY 2025 Annual Report to Congress Most Serious Problem. Progress during this period was affected by the lapse in appropriations and related operational impacts, including reduced staffing capacity, reassignment of work and priorities, and a reevaluation of TAS’s approach to managing systemic advocacy objectives and associated initiatives.

Quarter 2 Updates

TAS determined that the most effective course of action for this Systemic Advocacy Objective (SAO) was to elevate the issue to a Most Serious Problem (MSP) in the FY 2025 Annual Report to Congress. TAS has provided the IRS with the following recommendation to further address this issue, as outlined in MSP Centralized Authorization File, Recommendation:

Study ways to shorten and mitigate CAF “pending review” suspensions. Study and implement ways to shorten the duration of CAF investigations that place CAF numbers in “pending review” status. The IRS should also explore interim measures to minimize disruption to taxpayers and their representatives while reviews are ongoing, particularly when no confirmed compromise exists.

The IRS agreed to enhance publicly available guidance on IRS.gov to better explain the CAF pending review process and to conduct a Lean Six Sigma Opportunity (LSSO) Assessment to identify improvement opportunities in the process.

As a result of elevating this issue from an SAO to an MSP, TAS is closing the SAO and will instead track the IRS’s progress on implementing this recommendation through the Annual Report to Congress (ARC) Recommendations Tracker page.