Monthly CPA Newsletter: March 2026

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March 2026 Tax Update ERC Enforcement Intensifies -

What CPAs Need to Know

D Tax Accounting - CPA & Advisor Newsletter

The IRS has significantly escalated its enforcement efforts around the Employee Retention Credit (ERC), making it one of the most scrutinized pandemics-era programs. As audits expand and documentation standards tighten, CPAs and advisors should prepare clients for increased IRS activity throughout 2026.

IRS Expands ERC Audit Activity

The IRS is broadening its review of ERC claims, focusing on improper filings and unsupported eligibility. Current actions include:

  • Expanded audits and correspondence examinations

  • Requests for payroll, gross-receipt, and shutdown documentation

  • Targeted reviews of claims filed through ERC promoters

  • Investigations into preparer conduct

CPA Takeaway: Encourage clients to gather and organize ERC support now, even if they have not received an IRS notice.

Tighter Interpretation of Eligibility

The IRS is applying a stricter reading of ERC rules, especially for claims based on:

  • General economic slowdown

  • Broad or unverified supply-chain disruptions

  • Businesses that did not meet the gross-receipt decline threshold

Many claims submitted through aggressive marketing firms may not meet statutory requirements.

CPA Takeaway: Reassess eligibility documentation for clients with partial-suspension or supply-chain-based claims.

Promoter & Preparer Scrutiny Increases

The IRS is actively pursuing ERC promoters and reviewing preparer involvement in questionable filings. Civil penalties and heightened due-diligence expectations are now common.

CPA Takeaway: Remind clients that even if a third-party ERC company prepared the claim, the taxpayer is responsible for repayment if the credit is disallowed.

Documentation Will Drive Audit Outcomes

ERC audits rely heavily on documentation. Businesses should retain:

  • Payroll records for qualified wages

  • Financial statements showing gross-receipt declines

  • Government orders affecting operations

  • Internal records of operational disruptions

CPA Takeaway: Insufficient documentation may lead to disallowance, penalties, or repayment demands.

Enforcement Will Continue Through 2026

The IRS has stated that ERC enforcement will remain a priority.

Expect:

  • More audits

  • Faster IRS correspondence

  • Greater scrutiny of eligibility and documentation

CPA Takeaway: Proactive compliance reviews can reduce exposure and prepare clients for potential inquiries.

How D Tax Accounting Supports CPAs

We partner with CPAs and advisors to help navigate ERC enforcement, offering:

  • Eligibility review and documentation assessment

  • IRS correspondence and audit support

  • Representation and resolution strategies

As enforcement expands, professional guidance and organized documentation are essential to reducing risk.