Changes to Refund Payments, Payments to the IRS, and Mail Postmarks Create More Complexity for 2026 Filing Season

The IRS has announced the 2025 filing season will officially start on January 26, 2026. While many taxpayers will be looking forward to the potential for increased refunds thanks to the One Big Beautiful Bill Act’s passage, they may be surprised to learn of new changes impacting how they will receive those refunds. Additionally, changes to how the United States Postal Service will postmark mail and a shift toward electronic payments to the IRS may add further confusion for taxpayers this filing season.  

Executive Order 14247 

On March 25, 2025, President Trump signed Executive Order (EO) 14247, Modernizing Payments To and From America’s Bank. This EO requires two things: 

1. Effective September 30, 2025, payments made from the federal government, including tax refunds and social security payments, must be issued via electronic funds transfer methods, and 
2. Payments made to the government must be made electronically, but with no set effective date. 

For payments to taxpayers, the Treasury Department is authorized to continue issuing paper checks in certain circumstances, including: 

1. Where individuals do not have access to banking services or electronic payment services,  
2. For emergency payments where electronic payments could cause undue hardship (i.e., preliminary FEMA payments), and 
3. Other circumstances as provided by regulations or other guidance.  

To date, no “other circumstances” have been identified by the Treasury.  

Historically, certain tax forms have not had a direct deposit option, such as Form 1041 for trusts and estates, or Form 1120-F for foreign corporations. However, the IRS recently released a number of updated forms for tax year 2025 with a section added to provide account information for direct deposit, including the Form 1041 and Form 1120-F. These updates indicate that a broader range of taxpayers will be required to provide direct deposit information in 2026.  

For payments to the IRS, taxpayers may technically still make payments using paper checks until the IRS releases further guidance. However, taxpayers should be aware that the IRS has indicated that taxpayers who use paper checks “may” face longer processing times and delayed refunds. The IRS has several options available for taxpayers to make payments online. The Taxpayer Advocate has a good resource regarding these options at Tips on Electronic Payment Options Available to Taxpayers as the IRS Phases Out Paper Checks. 

Postmark Date Changes 

Additionally, the United State Postal Service recently changed when it will postmark mail. Mail will no longer be postmarked the day it is received; instead, it will be postmarked when it is sorted at a processing facility, which could be after the due date for tax purposes, potentially resulting in late payments. Taxpayers who insist on sending paper checks via mail to the IRS should be aware that they cannot count on their payment being postmarked within a day or two. The use of certified mail will be vital for taxpayers to show they mailed their payments in a timely manner.  

Taxpayers should be aware of all these changes going into the 2025 filing season to avoid delays in return and refund processing and even potential penalties. If you have questions about these changes, please contact us below.