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The Internal Revenue Service will begin automatically granting IRS First-Time Abatement penalty relief on January 1, 2026, expanding access to millions of taxpayers. The change addresses fairness concerns by reducing the burden on those with a good tax compliance history who often miss out on relief simply because they are unaware they need to request it.

How the IRS First-Time Abatement Works

Who Qualifies Under Good Tax Compliance Rules

The First-Time Abatement program provides penalty relief for taxpayers with good tax compliance. To qualify, individuals and businesses must have filed all required tax returns for the prior three years, complied with all current filing requirements, and avoided receiving other administrative waivers. The program applies only to the same return type, such as individual, business, or partnership returns.

Current Challenges: Notices, Requests, and Unpaid Tax

Under the existing system, relief is not automatic. Taxpayers must act after receiving an IRS notice or letter saying penalties were assessed. They may be required to file a formal written request or submit Form 843. Sometimes, they must contact the IRS or even call the IRS directly. Relief can apply even when there is unpaid tax, though interest and other penalties continue to accrue until full payment. These requirements mean many taxpayers—especially those without representation—cannot access the relief they legally deserve.

What Changes in 2026

Starting in tax year 2026, the IRS will reprogram its systems to automatically identify eligible taxpayers. Instead of requiring a manual request, the system will determine relief using account data and compliance history. This expansion will cover failure to file, failure to pay, deposit penalties, and information return penalties. Only those who do not qualify will receive an IRS notice, which will include guidance on pursuing reasonable cause relief or providing an acceptable reason for abatement.

Why Penalty Relief Matters in Tax Law

The First-Time Abatement program was created to give taxpayers with a record of good tax compliance a second chance when they make a mistake. It applies to individuals, estates, and business filers who meet eligibility standards, such as filing all required tax returns for the prior three years and staying current with ongoing tax obligations.

For years, the program required taxpayers to file a request actively, often after they received a notice or letter from the IRS assessing penalties. Those with tax professionals or prior knowledge of the program were more likely to benefit, while others remained unaware. As a result, only about 2% of eligible taxpayers accessed relief in a recent tax year, leaving millions to pay assessed penalties despite qualifying.

The National Taxpayer Advocate, an independent organization within the IRS, has long argued that fairness in tax law demands systemic automation. Reports have highlighted that taxpayers who fail to claim relief often still meet all the filing requirements and would have been entitled to it under the law. Official IRS pages, usually marked as “page last reviewed or updated,” note that relief is available for those who comply, but access remains uneven.

IRS and Taxpayer Advocate Perspectives

IRS Statement on Modernization and Relief

In a recent announcement, the IRS emphasized that automating penalty relief requires significant technical updates to its aging computer systems. The agency explained that these changes must integrate with existing compliance tools to accurately determine relief and prevent errors in applying assessed penalties. “We are working to ensure taxpayers who may qualify receive relief without the need to call the IRS or submit additional forms,” the statement said. Officials added that automation will streamline reviews of tax returns, help avoid duplicate claims for the same return type, and ensure consistency when taxpayers file under different circumstances.

National Taxpayer Advocate on Reasonable Cause and Fairness

National Taxpayer Advocate Erin Collins welcomed the move, describing it as a long-overdue fix for systemic inequities. She noted that millions of taxpayers with a good tax compliance history are currently missing out on relief. “Automating First-Time Abatement reduces burden, ensures fairness, and allows taxpayers who acted in good faith but made a mistake to focus on meeting their ongoing tax obligations,” Collins said in her blog. She also stressed that reasonable cause will remain available for those with additional facts, such as natural disaster disruptions, medical emergencies, or other facts that qualify as an acceptable reason under tax law.

Tax professionals also noted that this reform will help small businesses, partnership returns, and even estate filers who often struggle with the cost of representation. By embedding fairness directly into the system, the IRS reduces the need for taxpayers to provide extensive writing or documentation to explain their account history, obligations, or prior filing errors.

What Taxpayers Should Do Now

Requesting Relief Before 2026

Until automation takes effect in 2026, taxpayers who believe they may qualify for First-Time Abatement must act manually. They can file Form 843, respond to an IRS notice or letter saying penalties were assessed, or contact the IRS by phone. Relief can apply even if there is unpaid tax, but payment obligations and interest will continue until balances are resolved. Taxpayers should keep all the facts and documentation if the IRS needs to determine eligibility.

Tax Tips for Good Tax Compliance

A practical tax tip is always to file returns on time, even if full payment cannot be made, to preserve a record of good tax compliance. Those who experienced a natural disaster or other extraordinary circumstances may qualify under reasonable cause provisions. Maintaining accurate accounts and meeting filing requirements increases the chance of relief while minimizing the risk of different penalties. Updates and official guidance, often marked as “page last reviewed or updated” on IRS.gov, will provide the latest instructions as the 2026 implementation date approaches.

Official Sources for Tax Returns and Penalty Relief

For readers seeking authoritative guidance on eligibility, filing procedures, and program updates, the following official resources provide the most accurate and timely information: