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Published:   |   Last Updated: February 11, 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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Objective 20

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.

 

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