ITIN›Acceptance Agents’ Guide for Individual Taxpayer Identification Number
PART 5 – ACCEPTANCE AGENT COMPLIANCE
0125 Publ 4520 (PDF) · 2026-10-03 edition · updated 2026-10-04 · United States
What is the purpose of IRS Compliance reviews?
IRS conducts Compliance reviews of Certifying Acceptance Agents to assess the activities of the CAA and determine their compliance with rules and procedures described in Revenue Procedure 2006-10, Publication 4520 and the Acceptance Agent Agreement. Findings from Compliance reviews are issued by the ITIN Policy Section and may range from acceptance to termination based on the infraction. Refer to the exhibit at the end of this publication on Infractions and Sanctions.
What are the procedures for IRS verification of compliance with the Acceptance Agent Agreement?
The Acceptance Agent Agreement outlines the IRS’s expectation of CAAs and the required procedures. In particular, this enables the IRS to verify that the Agent has adequate processes in place to properly assist the applicants and ensure compliance with stated requirements. Verification of compliance to stated procedures does not constitute an examination of the Agent’s books and records.
What are the procedures for IRS verification of compliance with the “Certificate of Accuracy”?
A CAA must agree to furnish supporting documents to the IRS upon request. In order to conduct periodic compliance checks, the IRS may rely on sampling techniques and/or verification (by risk-based selection) with ITIN recipients to assure reliability of the CAA’s certifications, while ensuring the least amount of disruption and burden to the CAA.
The CAA Agreement will specify the manner in which IRS compliance checks will take place (either on site or through correspondence). The CAA shall also permit and cooperate with investigations or audits conducted by the Treasury Inspector General for Tax Administration (TIGTA) and the Government Accountability Office (GAO). The CAA must make available to TIGTA and GAO such documents as requested, which they are required to maintain under the applicable provisions of their CAA agreement. Failure to provide the requested information will constitute a breach of the agreement and result in immediate suspension from the program. Where the CAA resides outside of the United States, in appropriate cases, assistance may be requested from the tax authorities of the country where the Agent resides.
24 Acceptance Agents Guide
What are the procedures for IRS verification of compliance with Record Retention Requirements?
CAAs must satisfy record retention requirements that pertain to the issuance of ITINs. CAAs are required to retain copies of relevant documents for a period of 3 calendar years following the year in which the application is mailed to the IRS. Records can be hard copies or electronic copies.
The CAA shall permit and cooperate with compliance checks by the IRS and make available to the IRS requested documents that the CAA is required to maintain per the applicable provision of their agreement. Compliance reviews are conducted at the location identified by IRS. Documents to maintain in the client file include copies of the following:
Valid tax return (unless an Exception is met)
Completed Form W-7(COA)
Supporting documentation
Exception documentation
Intake sheet/interview notes
IRS Notices In addition to the documents above, the CAA is also required to maintain the following records:
Standard of Operations (SOP)
Employee training material and certifications
Forensic Training Certification
What are the Quality Standards that must be met by Certifying Acceptance Agents?
CAAs must satisfy quality standards to remain in the Acceptance Agent Program. If a CAA has a 10 percent or more error (reject or suspense rate) in filing Forms W-7, they may be subject to a compliance review. See What happens after a compliance review? later, for more information.
What happens after a compliance review?
A Certifying Acceptance Agent is subject to compliance checks by the IRS to determine their compliance with the rules, procedures and applicable laws related to the submission of Form W-7 applications and related tax returns. After a compliance review, IRS will issue a determination of their findings, see Exhibit K for more information. If the finding is probation, the CAA will be converted to an Acceptance Agent (AA) status for at least one year.
At the end of that probationary period, the rates must have improved by at least 50% to be reinstated as a CAA. If the rates have not improved, the Agent will remain as an AA for the remainder of the time the agreement is in effect. If by the expiration of their agreement the error and suspense rates have not improved, the AA will be suspended from the program and will be ineligible to reapply for a period of one year.
When can I be reinstated as a CAA?
If a CAA’s status was changed to an AA due to a compliance review, the organization will remain in AA status until a second compliance review is conducted. The AA must retain copies of all applicant documents (i.e. Form W-7, supporting identification documentation, exception documentation if applicable, the federal tax return, CP notices, etc.) and receive a favorable review to be reinstated as a CAA. If the AA compliance review determines that the AA is compliant with procedures, they can request to be reinstated as a CAA.
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