Form 3115 Automatic Consent Under Rev. Proc. 2015-13: Filing and 481(a)

Form 3115 automatic consent lets you change an accounting method without waiting for the IRS to approve it: you file the form with your tax return, send a duplicate copy to Ogden, Utah, and start using the new method that same year. Consent is treated as granted the moment you file, provided your change appears on the current IRS List of Automatic Changes and you meet every condition in Revenue Procedure 2015-13. There is no user fee and no acknowledgment letter.¹

What Automatic Consent Actually Means

Rev. Proc. 2015-13 sets up two paths for changing an accounting method. The non-automatic path sends your Form 3115 to the IRS National Office, costs a user fee of $13,900 or more for requests received after January 29, 2026, and requires you to wait months for a letter ruling before you can implement the change.² The automatic path skips all of that. If your change is on the government’s pre-approved list, the IRS has already decided it doesn’t need individualized review.

The tradeoff is silence. You never receive confirmation that your automatic filing was accepted. You are operating on the assumption that you followed the rules correctly, and if an auditor later determines you didn’t, the IRS can treat the change as unauthorized, require you to revert to the old method, and assess back taxes and interest. Accuracy at the filing stage is what protects you, because nothing about the process itself provides that protection later.

Whether Your Change Qualifies

Before you touch the form, confirm four things. Fail any one of them and you’re pushed into the non-automatic process.

Your Change Is on the Current List

The IRS publishes a master list of every change eligible for automatic consent, and each qualifying change is assigned a Designated Change Number that identifies its legal authority and transition rules. The current list is Revenue Procedure 2025-23, effective for Forms 3115 filed on or after June 9, 2025, which superseded Rev. Proc. 2024-23.³ If your specific change isn’t on this list, automatic consent isn’t available no matter how ordinary the change seems. The list is updated periodically to reflect new legislation, regulations, and court decisions, so verify you’re working from the most recent version before you file.

You Haven’t Changed the Same Item in the Past Five Years

You cannot use automatic consent if you made or requested a change for the same item within the previous five tax years.¹ The rule exists to stop taxpayers from toggling methods to manipulate taxable income. Check your records for the previous sixty months before filing.

It Isn’t a Final Year or a Section 381(a) Transaction

You generally cannot request an automatic change in the final year of a trade or business, or in a year involving a liquidation or reorganization to which Section 381(a) applies. Accounting method changes usually produce adjustments that spread over multiple years, and a terminating business has no future years to absorb them. Narrow exceptions exist, usually limited to changes required by law.¹

You Meet the Conditions Attached to Your Specific DCN

Beyond the general rules, each Designated Change Number in Rev. Proc. 2025-23 may carry its own conditions, and you must satisfy every one of them on the date you file. Missing a condition buried in the description of your particular DCN is one of the most common reasons automatic consent fails.

The Section 481(a) Adjustment

Changing methods means your old and new methods have produced different cumulative amounts of income or deductions over the life of the business. The Section 481(a) adjustment reconciles that difference so nothing gets taxed twice and nothing escapes tax. It is the single most important calculation on Form 3115: what would your total taxable income have been if you had always used the new method, compared to what you actually reported? The difference is your 481(a) adjustment.

How you take it into account depends on its sign:

A negative adjustment, which decreases income, is taken in full in the year of change.
A positive adjustment, which increases income, is spread equally over four tax years: the year of change and the following three.

The four-year spread is the practical reason to file voluntarily rather than wait. If the IRS catches an improper method during an examination, the entire positive adjustment may be required in a single year with no spread.⁴ If a business terminates before the four-year spread runs out, the remaining balance accelerates into the final year. That’s the same logic that restricts automatic changes in a final year to begin with.

How to File

Automatic consent requires two filings, not one. Both are mandatory.

Attach the original Form 3115 to your timely filed federal income tax return, including extensions, for the year of change.
Send a signed duplicate copy to the IRS in Ogden no later than the date you file the return.

The Ogden address is: Internal Revenue Service, Ogden, UT 84201, Attn: M/S 6111.⁵ The duplicate can be mailed, sent by private delivery, or faxed. Certified mail with a return receipt is inexpensive proof of timely delivery if the IRS later questions it.

Filing your return electronically doesn’t eliminate the duplicate. Most tax software lets you attach Form 3115 as a PDF to the e-filed return, which satisfies the first requirement, but the Ogden copy still has to go separately. Skipping the duplicate is not a minor oversight; it can be grounds for the IRS to treat the change as if consent was never granted.¹

On the form itself, the pieces that most often decide whether the filing holds up are the Designated Change Number, the narrative description of the current and proposed methods with citations to the authorizing Code sections, and the 481(a) calculation shown in Part IV with workpapers thorough enough to survive an audit years later. Errors in the 481(a) calculation or inconsistencies between the method descriptions and the DCN can cause the IRS to reject the filing.⁶ The current form and instructions are available on the IRS website.⁷

Who Has to Sign

Signature rules turn on entity type. Corporations need an officer with personal knowledge of the facts and authority to bind the entity. Partnerships need a general partner or authorized LLC member. Joint returns need both spouses. Estates and trusts need the fiduciary. A paid preparer who helped complete the form must also sign in addition to the authorized individual.⁶

Filing While Under IRS Examination

Being under audit does not automatically disqualify you from an automatic change, but it limits when you can file and still receive audit protection, which is the shield that keeps the IRS from adjusting the same item for years before the year of change. Two windows exist for examined taxpayers who want that protection.

A three-month window if you’ve been under examination for at least 12 consecutive months, running from the 15th day of the 7th month to the 15th day of the 10th month of your tax year. For a calendar-year taxpayer, that is roughly mid-July through mid-October.
A 120-day window after an examination ends, provided a new examination hasn’t started and the item you’re changing wasn’t an issue under consideration during the prior exam.

In both cases, the method you want to change cannot already be an issue under consideration by the examining agent.¹ The windows give examined taxpayers room to fix unrelated methods; they don’t let anyone resolve an active audit dispute through the back door.

If You Missed the Deadline

If Form 3115 didn’t go in with your return, the options narrow, and neither is guaranteed.

Under Regulations Section 301.9100-2, you may get an automatic six-month extension from the original due date of your return, not the extended due date, to file Form 3115. This extension applies only to automatic change requests and requires you to meet the conditions in Section 6.03(4)(a) of Rev. Proc. 2015-13.⁶

Past that six-month window, relief moves to Regulations Section 301.9100-3, which the IRS grants only in “unusual and compelling circumstances.” You pay a user fee just for the extension request, separate from any fee for the underlying change, and it runs through the private letter ruling process rather than a checkbox on a form. Practitioners generally treat this as a last resort.

Rev. Proc. 2015-13 also gives the IRS National Office discretion to let a taxpayer who filed a defective automatic Form 3115 correct it and amend affected returns rather than losing consent altogether. Whether the IRS uses that discretion depends on the nature and severity of the defect.¹

1
Internal Revenue Service. Revenue Procedure 2015-13 – Procedures for Changing Methods of Accounting
2
Internal Revenue Service. Internal Revenue Bulletin No. 2026-1
3
Internal Revenue Service. Revenue Procedure 2025-23 – List of Automatic Changes
4
Internal Revenue Service. Internal Revenue Manual 4.11.6 – Changes in Accounting Methods – Section: 4.11.6.5.3 Spread Periods for IRC 481(a) Adjustments
5
Internal Revenue Service. Where to File Form 3115
6
Internal Revenue Service. Instructions for Form 3115 (12/2022)
7
Internal Revenue Service. About Form 3115, Application for Change in Accounting Method