A bookkeeping firm checklist for Form 8655 reporting agent authorization

This page is general information, not legal advice. About Form 8655 and the current Form 8655 PDF are the texts to read. Have counsel review your authorization process before you treat this as the firm's process. This page does not invent which returns Form 8655 covers beyond those IRS pages, and it does not walk through any e-file product's screens.

Use Form 8655 to authorize a reporting agent to sign and file certain returns; make deposits and payments for certain returns; receive duplicate copies of tax information, notices, and other written or electronic communication regarding any authority granted; and provide the IRS with information to aid in penalty relief determinations related to the authority granted on Form 8655. (About Form 8655)

The current Form 8655 PDF is where you mark the return series. Line 15 is authority to sign and file. Line 16 is authority to make deposits and payments. This page does not reprint that list, because the form is the current list. Open the PDF before you tell a client which employment tax forms you can e-file for them. (Form 8655 PDF)

Publication 3112 describes a Reporting Agent as a company (not an individual) that performs payroll services for other businesses. Reporting agents must submit Form 8655 to the IRS prior to or when they submit an IRS e-file application. If you do not have an EFIN yet, that application is the EFIN application guide. (Publication 3112, E-file provider services)

The Form 8655 PDF says reporting agents must file returns electronically except as provided under Rev. Proc. 2012-32, and must make deposits and payments electronically, generally through EFTPS. An authorization does not relieve the taxpayer of the responsibility to ensure that all tax returns are filed and that all deposits and payments are made. The reporting agent must notify the client of that fact, in writing, upon entering into the agreement and at least quarterly after that, and must recommend that the client enroll in EFTPS to view deposits and payments made on the client's behalf. (Form 8655 PDF)

• Send Form 8655 for signature after the engagement says you are the reporting agent, and before you e-file the returns listed on the form.
• Use the starting period format the form requires: YYYY/MM for quarterly returns (MM is the last month of the quarter), YYYY for annual returns, and YYYY/MM for the month deposits and payments begin.
• No authorization is granted for periods before the period indicated on the form.
• The signer must be a person the instructions allow for that entity (owner, officer, partner, fiduciary, and the other cases on the PDF).
• File the signed form where the instructions say: mail to the Ogden Accounts Management Service Center address on the form, or fax to the number printed there. The PDF says to send no more than 25 forms in a single fax transmission.

Put 8655 on the same onboarding packet as ledger access only when payroll filing is in the letter. The bookkeeping onboarding checklist already has a payroll access row. Authority to file is this form, not the payroll login.

Once Form 8655 is signed, any authority granted is effective beginning with the period indicated and continues indefinitely unless terminated or revoked by the taxpayer or the reporting agent. Disclosure authority is effective upon taxpayer signature and IRS receipt of the form. Authority granted on Form 8655 does not revoke and has no effect on Form 2848 or Form 8821. (Form 8655 PDF)

To increase authority, submit another signed Form 8655 completing lines 1 through 14 and any line you want to add. To decrease authority, send a signed written request to the same address. Filing a new Form 8655 that names a new reporting agent terminates the prior agent's authority beginning with the period on the new form. The prior agent still has disclosure authority for earlier periods unless specifically revoked. To revoke, send a copy of the previously executed form, sign it again under the original signature, and write REVOKE across the top. If you do not have a copy, send a signed statement that names the agent and says the authority is revoked. (Form 8655 PDF)

Build revoke into disengagement and into the client offboarding checklist. Do not leave 8655 live after you no longer run payroll for that EIN.

One row per client EIN. Duplicate a row only if you truly have two live authorizations that the IRS still treats as separate.

Download the do we need 8655 checklist and authorization roster. W-2 prep for clients you still serve is the year end payroll W-2 checklist. The tax season operator can draft the chase when a signed 8655 is still missing. Your staff approve what goes out. Your CPA reviews and signs every return.