The Reporting Agent List is the client roster you attach to Form 8655 so the IRS knows exactly which employer accounts your authorization covers. Build it right and the authorization works; get a name or EIN wrong and that client silently drops off, leaving you unable to file or deposit on their behalf until you fix it. Every entry must match IRS records exactly, follow the format in Publication 1474, and travel with the signed Form 8655 to the RAF team in Ogden.
What the List Does
Form 8655 authorizes a reporting agent to sign and file certain returns and to make federal tax deposits and payments through EFTPS for a client.1Internal Revenue Service. Form 8655 – Reporting Agent Authorization The list is what connects that authorization to real taxpayers. Without a correct entry on the list, the IRS has no way to tie the agent’s actions to a specific employer account, and the authorization fails for that client.
The data on the list has to match the IRS master file. A name shortened to a DBA, an EIN with a transposed digit, an outdated address from a prior entity — any of these causes the record to be rejected or the client to be dropped. Fixing it after the fact costs weeks.
What Each Client Entry Requires
Every client on the list needs three fields, and all three must match what the IRS already has on file:
- Legal name of the business, exactly as registered with the IRS. Trade names, abbreviations, and DBAs that differ from the master file will cause rejections.
- The nine-digit Employer Identification Number assigned to that business. This is the primary identifier the IRS uses to link agent actions to the correct account.
- The complete mailing address the IRS has on file for the business.
Keep the file layout clean. Use separate columns for name, EIN, and address, without merged cells or added fields. Simpler files produce fewer processing errors.
Verify EINs Before You Submit
Most preventable rejections start here. Clients routinely transpose digits, hand over an EIN from a prior business entity, or confuse their federal EIN with a state tax ID. Copying numbers from client-provided documents without checking them against IRS records is the single most common cause of list failures.
The best source is the CP 575 notice the IRS issued when the EIN was originally assigned. It shows the EIN and legal name exactly as they sit in IRS systems. The IRS issues the notice only once, so if a client has lost theirs, they can request an entity transcript or call the IRS business and specialty tax line to request Letter 147C, which confirms a previously assigned EIN.2Internal Revenue Service. Employer Identification Number
For agents handling large rosters, the IRS Taxpayer Identification Number Matching service validates TIN-and-name combinations before filing. It’s available in interactive and bulk formats and requires enrollment on the IRS Payer Account File database.3Internal Revenue Service. Taxpayer Identification Number (TIN) Matching Run the list through TIN Matching before you package it for submission. Mismatches caught here take minutes; mismatches caught after submission take weeks.
Formatting to Publication 1474
The list must follow the technical formatting specifications in IRS Publication 1474, the technical guide for reporting agent authorizations and federal tax depositors.4Internal Revenue Service. Publication 1474 – Technical Specifications Guide For Reporting Agent Authorization and Federal Tax Depositors Pull the current version before building the file; the specs cover record layout, field lengths, and the acceptable submission media, and they’re what the Ogden processors check against.
Where and How to Submit
Form 8655 and the accompanying list go to a single location regardless of where the agent is based:
Internal Revenue Service
Accounts Management Service Center
MS 6748 RAF Team
1973 North Rulon White Blvd.
Ogden, UT 844041Internal Revenue Service. Form 8655 – Reporting Agent Authorization
Fax submissions go to 855-214-7523. Send no more than 25 forms in a single transmission, and the IRS recommends computer-based faxing over a physical fax machine when possible.1Internal Revenue Service. Form 8655 – Reporting Agent Authorization Publication 1474 also permits submission on compact disc.4Internal Revenue Service. Publication 1474 – Technical Specifications Guide For Reporting Agent Authorization and Federal Tax Depositors
A few practical notes. Form 8655 must reach the IRS before or at the same time as your IRS e-file application.5Internal Revenue Service. Reporting Agent Technical Fact Sheet Keep a complete copy of every Form 8655 and the full list you sent. If you fax, save the confirmation. If you mail, use a trackable method. When a client’s authorization goes missing six months later, you’ll need proof of what you submitted and when.
Electronic Signatures
The IRS accepts electronic signatures on Form 8655. The form instructions direct agents to Publication 1474, Section 01.03, for the approved authentication methods and the additional items that must appear on an electronically signed form.1Internal Revenue Service. Form 8655 – Reporting Agent Authorization Keep evidence of the authentication steps for every signed form. For agents onboarding dozens of clients at once, e-signatures dramatically speed up the process compared to collecting wet signatures on paper.
Updating the List: Adding and Removing Clients
Client rosters change constantly. New businesses sign on, existing clients leave, and legal names change after mergers or restructurings. Each event requires an update.
To add a client, submit a new Form 8655 signed by that client, along with an updated list identifying the addition. The same formatting and verification standards apply. Make clear that the submission updates an existing authorization rather than opening a new one.
Removing a client works differently depending on who initiates it. If the taxpayer wants to revoke, they send a copy of the originally executed Form 8655 to the Ogden address, re-sign it under the original signature, and write “REVOKE” across the top. If the taxpayer no longer has a copy, they can send a written statement identifying the reporting agent by name and address and stating that the authority is revoked.1Internal Revenue Service. Form 8655 – Reporting Agent Authorization
If the agent wants to terminate authority for a client, the agent files a signed written statement with the IRS identifying the taxpayer’s name and address and the authorization being withdrawn. Agents can also use the delete process described in Publication 1474.1Internal Revenue Service. Form 8655 – Reporting Agent Authorization Either method goes to the same Ogden address or fax number used for the original submission.
Processing Time and the RAF
Once the IRS receives the forms and list, the data is entered into the Reporting Agents File, the database maintained at the Ogden campus that stores reporting agent and client records.6Internal Revenue Service. Reporting Agents File (RAF) Allow substantial processing time before expecting to file or deposit for new clients. Don’t assume authority is active until the IRS confirms the request was accepted.
Plan the submission timeline so it doesn’t collide with quarterly filing deadlines. Submitting a batch of new Form 8655s in mid-March and expecting to file first-quarter 941s by April 30 is cutting it dangerously close.
What the List Doesn’t Do
Two boundaries matter when you hand the list to a client or set expectations internally. First, Form 8655 is not a Power of Attorney. The reporting agent authorization does not let the agent represent clients before the IRS, which means no penalty abatement requests, no installment agreement negotiations, no audit or appeals representation, no consents extending the assessment period, and no refund checks.7Internal Revenue Service. Reporting Agents File Tips and Tricks Representation requires a separate Form 2848, and only if the agent is otherwise qualified to practice before the IRS.
Second, listing a client does not shift legal responsibility. The IRS holds the taxpayer accountable for timely filing of all returns and timely payment of all deposits, even when a reporting agent handles those tasks.1Internal Revenue Service. Form 8655 – Reporting Agent Authorization If the agent files late or makes a wrong deposit, the penalty lands on the employer’s account. Spell that out at onboarding; clients who understand it stay engaged with their payroll tax obligations rather than treating the agent relationship as a reason to stop paying attention.