Published: February 11, 2026 | Last Updated: March 5, 2026

Complete Processing of All Employee Retention Credit Claims and Ensure Taxpayer Rights Are Protected

The IRS must complete processing of all ERC claims while ensuring taxpayer rights are protected, particularly in light of statutory filing deadlines and the moratorium on new claim processing.

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TAS Recommends

To protect taxpayer rights and ensure efficient and fair administration of the ERC program, TAS recommends

that the IRS:

Recommendation 6-1

Commit to Completing Processing of All Remaining ERC Claims: Complete processing all remaining ERC claims by the end of CY 2025.

Recommendation 6-2

Prioritize Claims From Taxpayers Facing Financial Hardship: Prioritize processing ERC claims from taxpayers experiencing financial hardship, followed by claims processed in the order received.

Recommendation 6-3

Allocate Sufficient Resources to Review Disallowance Notice Cases: Devote sufficient resources to quickly and efficiently review and process taxpayer responses to ERC disallowance notices.

Recommendation 6-4

Track ERC Claims Affected by the Two-Year Statute of Limitations: Track ERC claims affected by the two-year statute of limitations under IRC § 6532 and notify and educate taxpayers on the consequences of the deadline expiring and the options available for extending the deadline.

Quarterly Updates

No updates to report for the first quarter of FY 2026. Progress during this period was affected by the lapse in appropriations and operational impacts, including reduced staffing capacity, reassignment of work and priorities, and reevaluation of TAS’s approach to managing systemic advocacy objectives and associated initiatives. TAS is refining its plans, quarterly activities, and success measures and will resume providing updates in the second quarter, including reporting any outcomes achieved during the first quarter.

Status

Return to FY26 Objective Statuses