Section 01. — Publication 1474 — Technical Specifications

Section 01.01 Reporting Agents must submit Reporting Agent’s Lists and accompanying Forms 8655 according to the specifications provided in this publication. Taxpayers use Form 8655 to give the required Authorization for Reporting Agents to file/sign client/ taxpayer employment tax returns and pay client/taxpayer tax according to the guidelines set forth in 2012-32, 2012-34 I.R.B. 267. Reporting Agents must comply with requirements to file/sign certain client/taxpayer employment tax returns and/or pay certain client/taxpayer tax electronically. For related information regarding IRS’s e-file Program, refer to Publication 3112, IRS e-file Application and Participation, and Rev. Proc. 2007-40, 2007-26 I.R.B. 1488. For related information regarding the Electronic Federal Tax Payment System (EFTPS), refer to Publication 4169, Tax Professional Guide to Electronic Federal Tax Payment System, Rev. Proc. 2012-33, 2012-34 I.R.B. 272, and Rev. Proc. 97-33, 1997-2 C.B. 371. Copies of these publications and revenue procedures are available on the Internet at www.irs.gov or by calling (800) TAX-FORM ((800) 829-3676).

A new Authorization must be submitted to the Service for any increase or decrease in the scope of the authority of a Reporting Agent to act on behalf of the taxpayer, but the preceding Authorization regarding the taxpayer and the Reporting Agent shall remain in effect except as modified by the new Authorization. A new Authorization must also be submitted to the Service if a taxpayer appoints a new Reporting Agent. Receipt by the Service of an Authorization designating a new Reporting Agent terminates the authority of the prior Reporting Agent for all purposes for tax periods beginning on or after the effective date of the new Authorization. An Authorization designating a new Reporting Agent also terminates the authority of the prior Reporting Agent to receive duplicate copies of notices. For the tax periods beginning before the effective date of the new Authorization, the prior Reporting Agent retains the authority specified in the prior Authorization unless the taxpayer explicitly revokes the prior Authorization.

An Authorization does not relieve the taxpayer of the responsibility (or from liability for failing) to ensure that all tax returns are filed timely and that all FTDs and FTPs are made timely. RA’s are required to provide a written statement in this regard to each taxpayer when it enters into a contract for services with the taxpayer and on at least a quarterly basis for as long as the RA provides services to the taxpayer. See Section 5.05 of Rev. Proc. 2012-32, 2012-34 I.R.B. 267 for more information.

Section 01.02 The initial Reporting Agent’s List and accompanying Forms 8655 must be submitted prior to or at the same time as the Application to Participate in IRS e-file Program is submitted.

Section 01.03 The Reporting Agent’s List must be accompanied by the Forms 8655 signed by the taxpayer or authorized representative (See Rev. Proc. 2012-32, 2012-34 I.R.B. 267). An image on compact disc (CD), photocopy, or fax of the Forms 8655 is acceptable. Images provided on CD must be in Tagged Image File format (.tif).

New RAAs must be submitted on Form 8655 with a revision date of May 2005 or later, or on an approved substitute form as described in Publication 1167, General Rules and Specifications for Substitute Forms and Schedules.

An Authorization on the latest revision of Form 8655 is not required to replace an Authorization made on a prior revision, provided that:

The Authorization places no restriction on the medium for filing Forms 940, Employer’s Annual Federal Unemployment (FUTA) Tax Return, or Forms 941, Employer’s Quarterly Federal Tax Return, and
The RA advises its client that Forms 940/941 may be filed electronically, and provides the client with the option of rejecting electronic filing as the medium for filing these forms. The RA may use the most efficient and timely method of clearly providing this notification to a client. A client’s rejection of electronic filing for Forms 940/941 must be submitted in writing to the RA; and
The RA immediately removes any client from its electronic filing client base when the client rejects having Forms 940/941 filed electronically.

Section 01.04 Reporting agents may secure electronic signatures on Form 8655 using the following guidance. This is the currently the only guidance for electronic signatures on this form, and guidance for electronic signatures for other forms may not be applied to Form 8655.

Generally, a Reporting Agent securing an e-Signature for Form 8655 must exercise due diligence to ensure the taxpayer or their authorized representative is authorized to sign Form 8655 (as specified in Section 6.02 of Rev. Rev. Proc. 2012-32, 2012- 34 I.R.B. 267 and in the General Instructions for Form 8655) by authenticating the signor’s identity via one of the two approved methods specified in 1) below. The Reporting Agent must also capture and record an electronic signature of the taxpayer or their authorized representative using one of the two approved methods for electronically signed Forms 8655 specified in 2) below. The saved version of the e-signed Form 8655 must display evidence of the e-signature, as noted below.

There are currently two approved methods for Reporting Agents to authenticate the identity of the person signing Form 8655:

a. An authorized representative of the Reporting Agent must visually inspect an official

state or federal government-issued photo identification document to authenticate the identity of the taxpayer or authorized representative prior to their electronic signing of the Authorization. This visual inspection of official state or federal governmentissued photo identification must occur in the physical presence of the taxpayer or authorized representative in a Point of Sale (POS) environment. The Reporting Agent must document and retain a record that this visual inspection of official state or federal government- issued photo identification was completed at the time an e-Signature was secured for Form 8655. Reporting Agents are not permitted to secure an electronic signature for Form 8655 from the taxpayer or their authorized representatives in the event that their identity cannot be verified via inspection of official state or federal government-issued photo identification.

b. Alternately, for purposes of electronically signing Form 8655, the Reporting Agent

may contract with a third party provider offering commercial electronic signature authentication services to verify the identity of the taxpayer or their authorized

representative. Such services must include a feature wherein some information known only to the taxpayer or their authorized representative (e.g. name, address, and truncated SSN of the taxpayer or their authorized representative) is obtained from the taxpayer or their authorized representative in a secure environment and passed to the third party provider for a return of a pass/fail identity authentication result to the Reporting Agent. This third party authentication method may be utilized in either remote or Point of Sale (POS) environments. The Reporting Agent must document and retain a record that the third party authentication process yielded a “pass” result at the time an e-Signature was secured for Form 8655. Optionally, Reporting Agents may adopt more rigorous third party authentication protocols such as utilizing commercial authentication services posing multiple Knowledge Based Authentication (KBA) questions for response by the taxpayer or their authorized representative in a real time environment. A Reporting Agent adopting a more rigorous third party authentication protocol must document and retain a record that the third party authentication process yielded a “pass” result at the time an e-Signature was secured for Form 8655. Reporting Agents are not permitted to secure an electronic signature for Form 8655 from the taxpayer or their authorized representatives in the event that the third party provider returns a “fail” result to the Reporting Agent.

After verifying the identity of the taxpayer or their authorized representative as specified above, a Reporting Agent may secure an electronic signature by means (only) of one of the following two approved methods for e-Signatures on Form 8655:

a. The Reporting Agent may secure and record an electronic signature by capturing the

signature of a taxpayer or authorized representative for the purpose of signing Form 8655 on an electronic stylus device in a Point of Sale (POS) environment (only). The taxpayer or authorized representative must be informed that they are electronically signing the Authorization. The saved version of the e-signed Form 8655 must display an image of the captured e-signature.

b. The Reporting Agent may secure an electronic signature for the purpose of signing Form

8655 by presenting the taxpayer or authorized representative the option on an electronic device (computer, tablet, etc.) to select a checkbox agreeing that by doing so they are electronically signing Form 8655. This checkbox must be selectable by the taxpayer or their authorized representative; it cannot be pre-populated on the electronic device being utilized to secure the electronic signature of the taxpayer or their authorized representative. The taxpayer or authorized representative must be informed via language incorporated within the checkbox option itself or in close proximity (immediately preceding, directly next to, or immediately succeeding) to the check box item that by selecting the checkbox they are electronically signing the Authorization. In addition to recording the selection of the checkbox, the Reporting Agent must capture and record the date and time of the signature event and the IP address of the electronic device on which the electronic signature was captured. This electronic signature method for Form 8655 may be utilized in either a remote environment through a secure portal or in a Point of Sale (POS) environment. The saved version of the e-signed Form 8655 must display the date and time of the signature event and the IP address of the electronic device on which the electronic signature was captured.

Optionally, in addition to capturing the electronic signature event data described above, the Reporting Agent may choose to capture and record additional electronic data elements such as a signature facsimile created by a mouse device, a signature facsimile created by means of a generated font, a voice recording, etc. However, it is not permissible to substitute any optionally captured additional data elements for one of the two approved identity authentication methods for electronically signed Forms 8655 described above or in lieu of obtaining the agreement of the taxpayer or their authorized representative to electronically sign Form 8655 via the checkbox methodology described here.

Reporting Agents that adopt e-Signature methodologies discussed above are required to follow all other requirements for Authorizations, including but not limited to submitting Forms 8655 to the Internal Revenue Service as discussed in Section 01.03 of this publication and retaining a copy or reproducible image of each Form 8655 as discussed in Section 03.01 of this publication. Each submitted and retained e-signed Form 8655 must display evidence, as described above, of the e-signature; failure to include this required information may result in rejection of Form 8655.

However, Reporting Agents that adopt e-Signature methodologies discussed above and who are required to file Reporting Agent’s Lists electronically (exceeds the 100-per-week submission threshold described in Section 01.06 of this publication and in Rev. Proc. 2012-32, 2012-34 I.R.B. 267) will not be required to submit copies of such Authorizations when submitting the Reporting Agent’s List.

Section 01.05 The IRS will accept and process to the Reporting Agents File (RAF) Authorizations for electronic signature/submission of Forms 940, 941, 943, 944, 945 and amended or successor forms including Form 941-X, Form 943-X and Form 945-X.

The IRS will also accept and process to the RAF Authorizations for signing and filing on paper Forma 940-PR, Planilla Para La Declaración Anual Del Patrono–La Contribución Federal Para El Desempleo (FUTA), Forma 941-PR, Planilla Para La Declaración Federal Trimestral Del Patrono– La Contribución Federal Al Seguro Social Y Al Seguro Medicare, Form 941-SS, Employer’s Quarterly Federal TaxReturn, Form 943, Employer’s Annual Federal Tax Return for Agricultural Employees, Forma 943-PR, Planilla Para La Declaración Anual De La Contribución Federal Del Patrono De Empleados Agricolas, Form 944, Forma 944(SP), Declaración Federal Anual de Impuestos del Patrono o Empleador, Form 945, Annual Return of Withheld Federal Income Tax, Form 1042, Annual Withholding Tax Return for U.S. Source Income of Federal Income Tax, Form CT-1, Employer’s Annual Railroad Retirement Tax Return, and any amended or successor forms including Form 941-X, Adjusted Employer’s ANNUAL Federal Tax Return or Claim for Refund, Form 943-X, Adjusted Employer’s Annual Federal Tax Return for Agricultural Employees or Claim for Refund, Form 944-X, Adjusted Employer’s QUARTERLY Federal Tax Return or Claim for Refund, Form 945-X, Adjusted Annual Return of Withheld Federal Income Tax or Claim for Refund, and Form CT-1 X, Adjusted Employer’s Annual Railroad Retirement Tax Return or Claim for Refund.

The IRS will accept and process Authorizations for submissions of Federal Tax Deposits (FTDs) and Federal Tax Payments (FTPs) for Forms 940, 941, 940, 941, 943, 944, 945 and amended or successor forms including Form 941-X, Form 943-X and Form 945-X

The IRS will accept and process Authorizations for disclosure of confidential taxpayer

information corresponding to the forms authorized for signing, filing, and/or making payments. The IRS will also accept and process Authorizations for disclosure of confidential taxpayer information to assist in responding to certain IRS notices relating to the Form W-2 and/or Form 1099 series information returns, and/or the Form 3921 or Form 3922 information returns. The authority for the Form W-2 series is limited to years 2004 and subsequent. The authority for the Form 1099 series is limited to years 2006 and subsequent. The authority for the Form 3921 or Form 3922 information returns is limited to years 2010 and subsequent.

Section 01.06 There are two methods of submitting the Reporting Agent’s List: electronically or on paper. If the number of client/taxpayer submissions exceeds 100 per week, the Reporting Agent’s List is required to be filed electronically. Effective December 2025, the IRS finalized its transition from Secure Data Transfer (SDT) service used for file transfers with external trading partners (ETP) to the new service, Secure Large File Transfer Business 2 Business (SLFT B2B). SLFT B2B is the only approved method for electronic submission of Reporting Agent’s Lists. Use of the SLFT B2B system requires the purchase of an electronic identity authentication certificate from a designated third party. At this time, the IRS is unable to support optional use of the SLFT B2B system for submission of Reporting Agent’s Lists by Reporting Agents that are not otherwise required to file electronically (exceeds the 100 per week submission threshold described above and in Rev. Proc. 2012-32, 2012-34 I.R.B. 267). This is true even if a Reporting Agent is approved for use of SLFT B2B for submission of electronic files for other purposes. This publication will be updated if it is later determined that the IRS can support optional use of the SLFT B2B system for the purpose of submitting Reporting Agent’s Lists.

Section 01.07 Reporting Agent’s Lists submitted electronically must be submitted in accordance with the specifications in Sections 04 and 05 of this publication.

Section 01.08 Reporting Agent’s Lists on paper must be submitted using the format indicated in Exhibit 2 of this publication or instructions in Rev. Proc. 2012-33 for Batch Filers and Bulk Filers. Reporting Agent’s Lists and Forms 8655 must be submitted in ascending numerical order by Employer Identification Number (EIN).

Section 01.09 The IRS will validate the information on the Reporting Agent’s List and the associated RAAs. If the Reporting Agent’s List was submitted electronically, the IRS will return electronic add/error lists. If the Reporting Agent’s List was submitted on paper, the IRS will return the paper listing reflecting add/error status. The validated Reporting Agent’s List will include the Name Control for each employer.

Section 01.10 The following items must be included in the Reporting Agent’s List. An example of the Reporting Agent’s List is provided in Exhibit 2.

Name and Address of RA
RA’s Employer Identification Number (EIN)
List Type - either Additions or Deletions. Separate lists must be prepared for additions and deletions.
Name of RA’s Contact Person
Phone Number of RA’s Contact Person
Client Account Number – this is an optional field for benefit of RAs.
Taxpayer’s Employer Identification Number (EIN)
Name Control – leave blank. This will be entered by IRS during processing.
Name and Address of taxpayer - this should match the name on IRS records. For a sole proprietor, enter the owner’s name.

Section 01.11 If the RA wishes to add or delete clients/taxpayers from its authorized list, the format for both the electronic file and the paper Reporting Agent’s List is the same as for the initial listing submission, except the list or file type is designated as “delete.”

Section 01.12 The RA should notify the IRS when the RA determines that it will no longer be filing tax returns or making FTD/FTP submissions for a taxpayer. This is accomplished by submitting a Reporting Agent’s List, type “delete,” either electronically or on paper.

Section 01.13 Paper Forms 8655 and Reporting Agent’s Lists must be sent to the full address shown below to ensure proper delivery for submissions of RAAs:

Form 8655 and Paper Reporting Agent’s Lists Delivery:

Internal Revenue Service Accounts Management Service Center MS 6748; RAF Team 1973 N. Rulon White Blvd. Ogden, UT 84404

Forms 8655 and paper Reporting Agent Lists may also be faxed to the RAF Team at 855-214-7523.