Deceased taxpayer account locks are 99.8% accurate, TIGTA says

Filing season always surfaces edge cases. One of the most disruptive? A return was rejected because the IRS shows the taxpayer as deceased.

A Feb. 23, 2026, Treasury Inspector General for Tax Administration (TIGTA) report confirms the system largely works as intended, but it also highlights programming gaps that directly affect practitioners.

Here’s what you need to know.

Quick take for tax pros

• 99.8% of deceased account locks reviewed were accurate.
• Over 13,500 accounts were locked in error despite no Social Security Administration (SSA) date of death.
• Nearly 31,000 deceased taxpayers had no lock due to an unprocessed SSA file.
• Programming fixes are scheduled for January 2026 and January 2027.
• Rejected e-files tied to deceased indicators still require careful resolution steps.

What the TIGTA report reviewed

The report, “More Than 99 Percent of Deceased Taxpayers’ Accounts Are Accurately Locked (Report No. 2026-400-004)”, evaluated how the IRS places and maintains deceased indicators on taxpayer accounts.

The IRS uses a deceased lock to prevent fraudulent returns from being filed using a deceased individual’s Social Security number (SSN). When the lock is present:

• E-filed returns are rejected
• Paper-filed returns are prevented from posting
• The IRS issues Notice CP01H, Tax Return Submitted with Locked Social Security Number (SSN)

As of October 2024, approximately 57 million taxpayer accounts had a deceased lock.

TIGTA reviewed nearly 6.9 million locks placed between October 2022 and October 2024 and found 99.8% were accurate, indicating strong system performance.

The remaining 0.2%, however, still has a measurable impact on taxpayers and the preparers who serve them.

Where the system broke down

TIGTA identified two main categories of issues.

1. Erroneous locks placed on living taxpayers

More than 13,500 taxpayers had a deceased lock placed on their account, even though SSA data did not show a date of death.

IRS management stated causes may include:

• Incorrect SSA data
• Taxpayer reporting errors
• IRS employee input errors
• Programming issues involving primary versus secondary taxpayers

One notable issue involved surviving spouses. If a secondary taxpayer’s death was noted on a joint return, programming errors sometimes failed to record the date of death on the proper account correctly.

The IRS reported reversing these erroneous locks in June 2025.

2. Deceased taxpayers without a lock

TIGTA also found nearly 31,000 taxpayers with an SSA-reported date of death whose accounts were not locked.

The cause? A January 2023 SSA update file was not processed.

Without the lock, those accounts were potentially vulnerable to refund fraud.

IRS management later expanded the review and identified over 24,000 additional affected accounts tied to the same file.

Those death dates were updated in April 2025; the accounts are expected to have locked during the January 2026 annual update.

What these account locks mean for your practice

Even with 99.8% accuracy, the remaining fraction translates to thousands of disrupted filings.

In practice, you may see:

• Rejected e-files for living clients
• Potential refund delays
• Confusion after a client receives Notice CP01H
• Secondary taxpayer mismatches on joint returns

A deceased-lock e-file rejection does not automatically mean SSA data is wrong.

The issue could stem from:

• A primary versus secondary taxpayer coding error
• A delayed SSA correction not yet systemically reversed
• A programming gap is scheduled for future implementation

Programming changes are expected:

• January 2026 to ensure secondary taxpayer dates of death are posted correctly
• January 2027 to ensure systemic reversal when SSA updates remove a date of death

Until those changes are fully operational, practitioners may experience occasional friction.

How to approach a CP01H situation

If a return is rejected due to a deceased indicator:

• Verify whether SSA records reflect a date of death
• On joint returns, confirm which spouse the indicator is attached to
• Determine whether documentation proving the taxpayer is alive is required
• Prepare clients for authentication steps and possible delays. Setting expectations early reduces frustration and helps maintain client trust.

Why TIGTA’s report is relevant today

Identity theft filters continue to tighten, and the IRS must balance fraud prevention with taxpayer burden.

TIGTA’s findings confirm the deceased lock system is operating at a high level. But even small error rates can create real filing-season disruptions, including rejected returns, delayed refunds, added client communication and increased administrative time.

When a deceased indicator appears, your role often shifts from preparer to problem solver, requiring disciplined documentation and a precise review of SSA data, along with proactive client communication.

NATP continues to monitor IRS processing updates and identity theft safeguards so members can respond quickly when issues like deceased account locks arise.