IRS Tightens Documentation for Partnership ITIN Applications

News · ITIN Effective 1 June 2026 Written up by SV Associates on 2 September 2026

The IRS has added a documentation requirement for a specific category of ITIN application. If you are applying for an ITIN because you are a partner in a US partnership or LLC, there is now something extra you need to give us.

What changed

Effective 1 June 2026, a Certifying Acceptance Agent submitting a Form W-7 for a client claiming Exception 1(a) — Partnership must include a copy of the part of the partnership or LLC agreement that shows:

• the partnership's name;

• its Employer Identification Number (EIN);

• the applicant's name and signature.

The extract must also establish that the applicant is a partner in a partnership conducting business in the United States. The EIN can appear on the agreement itself, or be evidenced by the IRS confirmation notice — a CP 575 series notice or a Letter 147C.

Why it changed

Earlier versions of Form W-7(COA), the Certificate of Accuracy a CAA submits, had fields where the partnership name and EIN could simply be written on the form. The August 2025 revision removed those fields.

So the information has not disappeared — it has moved. Instead of a CAA asserting it on the certificate, the IRS now wants the underlying document. From June 2026 the partnership box on the COA is optional, and the exception document itself is mandatory.

What this means if you are applying

Only Exception 1(a) partnership applications are affected. If you are applying for an ITIN as a spouse, a dependent, a property owner or under any other reason code, nothing about your application changes.

If you are applying as a partner, the practical effect is that you should have the relevant pages of the partnership or LLC agreement ready at the start rather than being asked for them later. An application submitted without them is liable to be rejected, and a rejection means rejoining the queue rather than correcting in place.

Two things are worth checking on your agreement before you send it:

• Your name is spelled exactly as on your passport. A mismatch between the agreement, the W-7 and the passport is a rejection reason in its own right.

• Your signature is actually on the page you send. The requirement is specific about this, and a signature block on an unsigned template does not satisfy it.