Changes to the Exception 1a ITIN application Process

The following email was sent to Certified Acceptance Agents by the IRS Program Office on January 28, 2026

You are receiving this email as a participant in the IRS Acceptance Agent Program as of January 25, 2026. We are writing to inform you of an upcoming procedural change regarding the submission of Form W-7 applications under Exception 1(a), Partnership Income.

Effective June 1, 2026, you will be required to include a copy of the portion of the partnership or LLC agreement displaying the partnership’s name, employer identification number (EIN), and applicant’s name and signature. The document must also show that the applicant is a partner in a partnership that’s conducting business in the United States per page 19 of Publication 1915, Understanding Your IRS Individual Taxpayer Identification Number ITIN (Rev. 12-2025) and page 30 of Publication 4520, ITIN Acceptance Agents’ Guide for Individual Taxpayer Identification Number (Rev. 12-2025). Updates to the Instructions for Form W-7 adding the applicant’s partnership agreement signature to the requirements are currently in progress.

The EIN may be written on the partnership agreement or printed on an included CP 575 series EIN confirmation notice or Letter 147C. Prior versions of the Form W-7 (COA) allowed for the inclusion of the partnership name and EIN on the form itself; however, our latest version (August 2025) removed those fields and updated the instructions on page 2. The section What is the purpose of the Form W-7-COA? now includes the following revised note: All supplemental documentation including support for residency, “Exception” criteria, or a denial letter from the Social Security Administration (if applicable) must be attached to Form W-7 and submitted to the IRS.

We recommend you begin implementing this change immediately to avoid any issues. Through May 31, 2026, any Forms W-7 submitted for Exception 1a with the prior versions of the Form W-7(COA) will be accepted; however, if you submit the current version, you will need to include the required documentation per the form instructions. Beginning June 1, 2026, your Exception 1(a) submissions must include the partnership exception documentation (with all required elements) no matter which version you use.

Please ensure all Responsible Party(ies) listed on your agreement are aware of this change. As always, we appreciate your continued participation and interest in the IRS Acceptance Agent Program.

The IRS has updated its Exception 1a ITIN policies effective June 1, 2026