An ITIN does not send a warning when it lapses, and most holders only find out when a return comes back slower with a credit missing.
When Does an ITIN Expire?
An ITIN expires on December 31 after the third consecutive tax year it was not used on a federal tax return. That is the IRS administrative rule stated on its ITIN renewal page and repeated in the Form W-7 instructions, and it applies to every active ITIN, including a pre-2013 number that was renewed.
The statute behind it, IRC Section 6109(i)(3)(A), sets a different date. It ties expiration to the day after the due date of the return for the third consecutive year of non-use, which falls in the following year. The IRS administers the earlier December 31 date, and that is the one to plan around, so neither date should be quoted as if it stated the other.
Two things count as use, and only two. Filing your own federal return with the ITIN on it keeps the number alive. So does appearing as a dependent on someone else's return, which the statute states directly. A Form 1099 or any other information return does not count, and an ITIN that has already expired can still be used on those information returns without triggering anything, because the non-use clock only ever watches federal tax returns.
Pre-2013 ITINs run on their own separate schedule. IRC Section 6109(i)(3)(B) and (C) set expiration dates of January 1, 2017, 2018, 2019 or 2020 depending on the year of issuance, and any of those numbers that has not been renewed is already expired. The older wave-based schedule tied to the middle two digits of the ITIN ran out with the group that expired December 31, 2020, covering middle digits 88, and 90, 91, 92 and 94 through 99 if assigned before 2013 with no renewal since. If your ITIN's only history is that old wave list, it is a closed question; the number 93 was never on it, and non-use is now the only live trigger going forward.
When Is Renewing an ITIN Not Required?
You renew an ITIN only when it will go on a federal tax return. There is no advance renewal, and leaving an expired ITIN alone costs nothing when nothing is being filed under it this year.
The IRS treats an ITIN used only on information returns, such as a Form 1099 reporting payments to you, as never needing renewal at all, and that number stays usable on those information returns after it expires. You also do not need an ITIN to request a filing extension or to pay estimated tax, so neither of those tasks forces a renewal either.
If your circumstances changed and you were issued a Social Security number instead, stop using the ITIN and do not renew it. The IRS asks you to write to Internal Revenue Service, Austin, TX 73301-0057, with your name, address and ITIN, a copy of your Social Security card, and a copy of your CP565 ITIN assignment notice if you kept it, so the two records get merged.
Checking whether your own number has lapsed starts with your own filing history, since the IRS points taxpayers to their IRS Online Account or to a CP48 notice, which the agency may mail when an ITIN on a return appears to be expiring. Neither channel is confirmed to reach every ITIN holder, so counting your own three years of non-use from memory is the more reliable check.
What Happens If You File With an Expired ITIN?
The return still gets processed, but the IRS holds back certain credits until the ITIN is renewed, and processing itself can run slower. The current IRS language is direct about the risk: there may be a delay in processing, certain credits may be unavailable until the ITIN is renewed, and the result can be a reduced refund or added penalties and interest on a balance due.
A 2020 IRS release, now archival, described the sequence the IRS followed at that time: the return got processed, the credits and exemptions tied to the expired number were disallowed, a notice went out by mail, and the credits and exemptions were restored once the renewal was complete. Treat that as past IRS guidance only. It predates OBBBA's own changes to which credits an ITIN can reach, covered below, and the current IRS page makes no promise of restoration.
What the current page does say is that you may face a delay, credits you may not be able to claim, a reduced refund, or penalties and interest. A renewal that has to go in with a paper return, because the return with the expired ITIN triggers the same attachment requirement covered next, runs on the same multi-week clock as a brand new application, and that clock stretches longer during filing season.
How Do You Renew an ITIN With Form W-7?
You check the renewal box on Form W-7, still pick a reason for needing the ITIN, and attach the return the renewed number is needed for. Lines 6e and 6f ask for the prior ITIN and the name it was issued under; check the no or don't know box if you cannot find the original number.
A federal return now has to be part of nearly every renewal package. The instructions state that all Form W-7 renewal applications must include a U.S. federal tax return unless an exception applies, which is a change from a few years ago, when the IRS accepted a renewal without a return attached. The W-7 goes on the front of the return, and if a spouse and dependents are renewing at the same time, all of their W-7 forms go on that same return.
The identity document standard for a renewal is the same one that applies to a first-time application, covered in full detail in our Form W-7 guide. A current passport works alone; without one, you need at least two documents, one with a photo, and every document must be unexpired. A name change since the ITIN was issued needs a marriage certificate or a court order, which can be a divorce decree.
Getting the Package to the IRS
Three RoutesMail it. Internal Revenue Service, ITIN Operations, P.O. Box 149342, Austin, TX 78714-9342. The return goes with it, W-7 on top, original or agency-certified identity documents attached. Mailed originals come back to you, and calling in after 60 days is a reasonable check if they have not.
Use a Certifying Acceptance Agent. A CAA authenticates your documents and returns them to you the same day, so your original documents never go in the mail. For a dependent, though, a CAA's authentication power is limited to a passport or a birth certificate, and every other document on the acceptable list still needs the mail or an appointment route.
Visit a Taxpayer Assistance Center. By appointment, an IRS employee reviews and returns original documents on the spot.
Processing takes 7 weeks under ordinary conditions, and 9 to 11 weeks if you file between January 15 and April 30 or from outside the country, where mail can add even more time on top of that. Call 1-800-829-1040 for a status check, or 1-267-941-1000 from overseas.
Can a Spouse or Dependent Renew Their ITIN?
Only if they are claimed for an allowable tax benefit on the return the renewal is attached to, or file a return of their own. That rule has applied to every ITIN application and renewal for a spouse or dependent since tax years after 2017, and it has not loosened.
The allowable benefits are a short, fixed list: a joint return with a spouse, head of household or qualifying surviving spouse status, the American Opportunity Credit, the premium tax credit, the child and dependent care credit, and the credit for other dependents. Simply naming a spouse or dependent on a return, without one of those benefits attached, does not qualify them to renew. That list still names the American Opportunity Credit because the W-7 instructions predate OBBBA; starting with tax year 2026, the taxpayer claiming the credit needs a Social Security number, and so does a student who is not the taxpayer or spouse, so the ITIN gets renewed while the credit it was renewed for slips out of reach.
A dependent also has to show U.S. residency to renew, separate from the benefit test. Two groups are carved out of that residency requirement: dependents of U.S. military personnel stationed overseas, and dependents from Canada or Mexico claimed for a benefit other than the credit for other dependents. A passport that carries no U.S. entry stamp needs an additional document to establish residency on its own.
A spouse claimed only through the election to file jointly with a nonresident spouse follows the same allowable-benefit path; our nonresident spouse election guide covers how that election itself works. And because personal exemptions for spouses and dependents are permanently zero after OBBBA, getting or renewing an ITIN for exemption purposes alone accomplishes nothing; the renewal only has a point when one of the listed credits or a joint return is actually in play.
Does OBBBA Change Which Credits an ITIN Can Reach?
Yes, and the credits most ITIN filers assume are unaffected are exactly the ones that moved. The One Big Beautiful Bill Act, P.L. 119-21, added Social Security number requirements to several credits that an ITIN holder previously could reach, phased in across two different tax years.
Starting with tax year 2025, OBBBA requires the taxpayer's own Social Security number to claim the child tax credit, so an ITIN parent filing single or head of household gets no child tax credit even for a child who has one. On a joint return at least one spouse needs a Social Security number, with the other spouse needing an SSN or ITIN issued by the due date. That sits on top of the child SSN rule, which has applied since tax year 2018. A child who only has an ITIN has been limited to the $500 credit for other dependents since 2018, because the statute treats a child denied the child tax credit for that reason as an ODC-eligible dependent. The family keeps that smaller credit; the benefit does not disappear entirely.
The child tax credit, education credit, and earned income tax credit guides each walk through the current-year numbers and phaseouts in full. What OBBBA changes here is narrower than a full loss of eligibility. The child and dependent care credit is not on the list above and still allows an ITIN parent and an ITIN-only dependent, since Congress did not add the same Social Security number test to that credit.
Check the Credit Before You Renew
Confirm which Social Security number requirement, if any, applies to the specific credit you are counting on before the renewal package goes out. A parent chasing the full child tax credit for a child who only has an ITIN will not get it after renewal either, no matter how clean the W-7 is; that credit needs a Social Security number specifically, and no other taxpayer identification number satisfies it. Renewing still matters for the ODC, for a joint return, and for the other allowable benefits, so the renewal itself is rarely wasted, but it will not retroactively unlock a credit the statute now reserves for an SSN.
Whether the due-date relief that lets a first-time ITIN application count as timely for the child tax credit also covers a renewal of an already-issued ITIN is not something the IRS has spelled out, and the 2025 Schedule 8812 instructions speak only to applying for a new ITIN. Treat that question as open, and do not assume a renewal gets the same benefit.
Where Does That Leave an ITIN Holder This Filing Season?
Three straight tax years without your ITIN on a federal return, your own or as someone's dependent, is enough to expire it on December 31 of that third year, and no notice goes out to tell you so. The practical step now is checking your own filing history first, then attaching Form W-7 to the return once you actually need it, since a renewal filed without a return in hand gets rejected under current rules. A second check belongs on the same list. Confirm which credit the renewal is even for, because the American Opportunity Credit, the Lifetime Learning Credit, and above all the child tax credit have each picked up a Social Security number requirement under OBBBA that a renewed ITIN still cannot satisfy.
A renewal that spans a spouse, a dependent, and more than one missed credit is easy to get half right without walking through each rule in order, and that is the file our international tax team takes on. Have questions about a lapsed ITIN or a credit that OBBBA moved out of reach? Contact TS CPA for a free consultation. We respond within the same day.
Official IRS and Government Sources
- IRS, How to Renew an ITIN
- IRS, Instructions for Form W-7
- IRS, Publication 1915
- IRS, Individual Taxpayer Identification Number
- IRS, Additional ITIN Information
- IRS, Last Round of ITINs Will Expire in 2020
- IRS, Instructions for Schedule 8812
- IRS, Child Tax Credit
- IRS, Revenue Procedure 2025-32
- IRC Section 6109, Cornell Law School LII
- IRC Section 24, Cornell Law School LII
- IRC Section 25A, Cornell Law School LII
- IRC Section 151, Cornell Law School LII
- IRC Section 32, Cornell Law School LII