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Published:   |   Last Updated: May 27, 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.

 

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.

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.

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.

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.

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.

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.

 

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.

Return to FY26 Objective Statuses