ITIN Expiration and Renewal: Form W-7, Filing, and Dependents

An ITIN renewal is done on Form W-7, the same form used for the original application, and it should be completed before you file your next federal tax return. If the number has gone unused on a return for three consecutive years, it has already expired, and filing with it will cause the IRS to strip tax credits from your return and hold up any refund. Renewing first is almost always faster than fixing the problem afterward.

How to Tell If Your ITIN Has Expired

Federal law expires an ITIN the day after the filing deadline for the third consecutive tax year in which it was not used on a return (either as filer or as a listed dependent).¹ An ITIN last used on a 2022 return would expire after the April 2026 deadline if nothing was filed for 2023, 2024, or 2025.

A separate rolling schedule set by the Protecting Americans from Tax Hikes (PATH) Act of 2015 phased out every ITIN issued before 2013, with the last of those numbers expiring on January 1, 2020.¹ If your ITIN was issued before 2013 and you never renewed, it is already expired. From here on, the three-year non-use rule is the only expiration trigger that matters.

The IRS mails Notice CP48 to taxpayers whose ITINs are approaching expiration, identifying the specific number, its expiration date, and how to renew.² Sample notices have gone out roughly four months before the expiration date. Not getting one does not mean you are safe. The notice goes to the last address on file, so a move without an address update means the letter may never arrive. If you cannot say for certain that your ITIN appeared on a return in each of the past three tax years, treat it as expired and renew.

What You Need for the Renewal Application

Renewal uses Form W-7 with the “Renew” box checked.³ Supporting documents must be originals or certified copies from the issuing agency. Photocopies and notarized copies are not accepted, and every document must be current and unexpired on the date you submit.

A valid passport is the easiest path because the IRS accepts it as standalone proof of both identity and foreign status. Submit the original passport or a certified copy from the issuing agency and no other documents are needed.³

Without a passport, you need at least two documents from the IRS’s accepted list, one proving identity and one proving foreign status, and at least one must have a photograph (with exceptions for young dependents). Documents that prove both identity and foreign status include a USCIS photo ID, U.S. visa, foreign military ID, national identification card, foreign voter registration card, civil birth certificate, medical records (dependents under 6), and school records (dependents under 24 if a student). Documents accepted for identity only include a U.S. driver’s license, U.S. military ID, foreign driver’s license, and U.S. state ID card.⁴ Applicants under 18 without a passport must include a civil birth certificate.

Do You Need to Attach a Tax Return

Usually, yes. The general rule is that Form W-7 gets attached to the front of a completed federal tax return and mailed together.³ If spouses or dependents are being renewed to claim a tax benefit, they must appear on the attached return along with any relevant schedule or form.⁵

Five exceptions let you renew without a return:³

Passive income (partnership income, interest, annuities, rental income, etc.) subject to third-party withholding or covered by a tax treaty.
Other income covered by a treaty (wages, honoraria, scholarships, fellowships, gambling), or taxable scholarship income without a treaty claim.
A home mortgage on U.S. real property triggering third-party mortgage interest reporting.
Involvement in the sale of U.S. real property by a foreign person as buyer, transferee, or withholding agent.
A non-U.S. representative of a foreign corporation needing an ITIN to meet e-filing requirements.

If none of those describe your situation, the return must be included or the IRS will reject the renewal.

How to Submit the Application

Three submission paths are available:

Mail the complete package to the IRS Austin Service Center at the address listed in the Form W-7 instructions. A trackable delivery service is worth the cost since original identity documents may be inside.⁶
Use a Certifying Acceptance Agent (CAA). A CAA is authorized to review and authenticate most documents at your appointment and return them to you on the spot, so originals never leave your hands. CAAs typically charge a service fee.⁶
Visit an IRS Taxpayer Assistance Center that offers ITIN services. Staff authenticate documents in person and return them before mailing the application.⁶

Processing runs about 7 weeks under normal conditions and 9 to 11 weeks during tax season (January 15 through April 30) or for applications from overseas.⁷ If nothing has arrived within those windows, call 800-829-1040 in the U.S. or 267-941-1000 internationally (not toll-free). TTY/TDD callers can reach the IRS at 800-829-4059.

Renewing Spouse and Dependent ITINs

When your own ITIN is up for renewal, the IRS allows you to renew ITINs for your spouse and dependents at the same time, even if theirs are not yet due. That is worth doing if any of them appear on your return for a tax benefit, because a dependent’s expired ITIN blocks credits tied to that person just as effectively as an expired filer number does.

Dependents claimed for tax benefits generally must also prove U.S. residency.⁸ A passport with a U.S. entry stamp does the job. If the passport has no entry date, supplemental proof depends on age:

Under 6: U.S. medical records, school records, state ID card, or visa.
Ages 6 to 17: U.S. school records, state ID card, driver’s license, or visa.
18 and older: U.S. school records (if under 24), state ID, driver’s license, visa, bank statement, rental statement, or utility bill showing a U.S. address.

Medical records must be dated within 12 months of the application, and school records must show term dates ending no more than 12 months from the application date. The residency requirement is waived for dependents of U.S. military personnel stationed overseas and for dependents from Canada or Mexico claimed for certain benefits other than the Credit for Other Dependents.⁸

What Happens If You File With an Expired ITIN

The IRS will accept and process a return filed with an expired ITIN, but it treats the number as invalid for credit purposes. Any credits claimed can be disallowed until the ITIN is renewed, shrinking your refund or wiping it out.⁵ A notice explaining the adjustment eventually arrives, but by that point the return is already stuck in extra processing.

The delay creates a second problem when the return shows tax owed. Interest and late-payment penalties keep running on the balance during the processing holdup, and those charges add up over months.⁵ File in January with an expired ITIN, wait months for a disallowance notice, then submit a renewal that takes another 7 to 11 weeks, and you can be nearly a year behind where you would have been by renewing first.

Credits that were disallowed can still be recovered. Once the ITIN is renewed, you can file an amended return within the general window (three years from the original filing date or two years from the date the tax was paid, whichever is later). Renewing before you file is simpler in almost every case.

What an ITIN Does Not Do

An ITIN exists for federal tax filing. The IRS is explicit that it does not authorize work in the United States, does not affect immigration status, and cannot be used as identification outside the tax system.⁷ It is not a substitute for a Social Security number, cannot be used on an I-9, and does not qualify anyone for Social Security benefits or the Earned Income Tax Credit. A child must have an SSN to qualify for the Child Tax Credit or Additional Child Tax Credit; ITIN dependents can support the Credit for Other Dependents, worth up to $500.⁹

One situation where you should not renew: if you obtained a Social Security number after your ITIN was issued. Contact the IRS instead so the agency can merge your tax records under the SSN.

1
Office of the Law Revision Counsel. 26 USC 6109 – Identifying Numbers
2
Internal Revenue Service. Notice CP48 – You Must Renew Your Individual Taxpayer Identification Number (ITIN)
3
Internal Revenue Service. Instructions for Form W-7 – Application for IRS Individual Taxpayer Identification Number
4
Internal Revenue Service. ITIN Supporting Documents
5
Internal Revenue Service. How to Renew an ITIN
6
Internal Revenue Service. How to Apply for an ITIN
7
Internal Revenue Service. Individual Taxpayer Identification Number (ITIN)
8
Internal Revenue Service. Instructions for Form W-7
9
Internal Revenue Service. Child Tax Credit