What to do if your CAF number is in “pending review”

The IRS has issued new guidance that every tax professional should note. Your Centralized Authorization File (CAF) number can now be placed in a “pending review” status under certain conditions. For tax professionals who frequently interact with the IRS, a CAF number review can be more concern than for those who do not regularly represent clients.

What is a CAF number?

Your CAF number is different from your PTIN or Social Security number. The IRS uses a nine-digit identifier to track your authority to represent clients and request confidential taxpayer information. Whenever you submit Form 2848, Power of Attorney, or Form 8821, Tax Information Authorization, your CAF number links you to the taxpayer. Without a valid CAF, the IRS may decline to speak with you about client matters or share sensitive information.

Why a CAF number may be reviewed

The IRS is strengthening security around CAF numbers to protect against identity theft and misuse. A number may be flagged for review if there is unusual login activity, a potential compromise, or suspicious behavior on a power of attorney or authorization form (such as inconsistent information or patterns suggesting fraud).

When this happens, the IRS places a “P” code on your CAF for pending review. During this time, IRS employees will not authenticate your authority through that CAF. You cannot use it to request transcripts, represent clients or receive taxpayer data. Think of it as a temporary freeze while the IRS checks whether your CAF is compromised.

What happens if you’re under review

If your CAF number is placed under review, you’ll be notified by letter. The letter may come from the IRS Criminal Investigation division and will outline the necessary actions you need to take. Typically, the IRS requires a notarized response within 30 days that includes personal identification details. In some cases, you may be asked to confirm your client list.

After review, the IRS will either restore your CAF number or cancel it. If cancelled, you’ll be issued a new CAF number and will need to submit new Forms 2848 or 8821 for each client, as authorizations do not automatically transfer to the new CAF.

Why this matters

Having your CAF number under review disrupts your ability to work with the IRS. Even if you have the proper forms on file, the agency will not treat your authorization as valid until the review is complete. This can cause delays in audits, appeals and other matters.

Adding to the challenge, the IRS does not always disclose why a number is under review. You may only discover the issue when you attempt to represent a client, and the IRS declines your request or upon receipt of the IRS letter.

Steps to protect yourself

• Safeguard your CAF number and avoid sharing it unnecessarily. You can review or apply for your CAF number online on your IRS Tax Pro account.
• Monitor how and where you access IRS systems since unusual patterns may trigger review.
• Respond quickly to any letter requesting notarized verification.
• Keep records of all client authorizations in case you need to reestablish authority under a new CAF.
• Stay alert for signs of suspension, such as IRS employees telling you they cannot confirm your authority.

Final thoughts

The IRS’ move to place CAF numbers in pending review status reflects its commitment to protecting taxpayer information and practitioner access. While not every tax professional will experience this issue, the possibility is real. A proactive approach, such as protecting your CAF, responding quickly to IRS requests and safeguarding client records, will help you navigate the process if your number is ever flagged.