As of 2026, the IRS has not changed ITIN eligibility rules. However, the IRS has updated its internal processing procedures for how ITIN applications (Form W-7) are reviewed and handled.
These changes don't alter who qualifies for an ITIN, but they do affect processing timelines and refund delays for foreign sellers.
What's changed:
- IRS response timeframes for missing documentation were extended (up to 120 days)
- Internal workflows for reviewing and batching ITIN applications were reorganized
- Documentation review and correspondence handling were clarified
- Additional internal review steps may apply when applications are incomplete or inconsistent
Why this matters:
- An ITIN is required to file a U.S. tax return
- Refunds cannot be issued without a valid ITIN
- Delays in ITIN issuance delay refunds
- Waiting until tax season increases risk of extended processing
ITIN rules haven't changed, but how the IRS processes ITIN applications has. For foreign sellers, timing and accuracy are more important than ever.
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Kat Rodgers
Foreign Tax CPA, LLC
Cocoa Beach FL
+1 (321) 784-8329
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