New ITIN Rules: Expiration, Renewal, and Tax Credits

The new ITIN rules that matter most to current and prospective holders are a rolling expiration system, stricter document standards, and tighter limits on which tax credits an ITIN qualifies you for. Your Individual Taxpayer Identification Number can now lapse two different ways: by going three straight years without appearing on a filed federal return, or by having middle digits the IRS has scheduled for retirement. Notarized copies of your identity documents are no longer accepted. And while an ITIN still lets you file, it will not get you the Child Tax Credit or the Earned Income Tax Credit — those require Social Security numbers.

The Two Ways Your ITIN Can Expire

Both expiration triggers run independently. Check your number against each.

Three Years Without a Return

Any ITIN left off a federal tax return for three consecutive tax years expires on December 31 of that third year. Whether you earned income, and whether that income was under the filing threshold, is irrelevant. What counts is whether a return was filed using the number.¹ Filing at least once every three years is the only way to keep an ITIN active.

Middle-Digit Retirement

Separately, the IRS has been retiring older ITINs on a schedule keyed to the fourth and fifth digits of the number (the format is 9XX-XX-XXXX). ITINs with middle digits 70 through 87 expired in earlier rounds. Middle digits 88 expired at the end of 2025. ITINs with middle digits 90 through 99 that were issued before 2013 have also expired.² If your ITIN sits in any of those ranges and you have not renewed, it is inactive.

What Happens If You File Anyway

The IRS will still process a return submitted with an expired ITIN, but it strips out credits tied to the number until you renew. The Child Tax Credit, the Credit for Other Dependents, and the American Opportunity Tax Credit are all disallowed on an expired ITIN, and the IRS mails a notice explaining what was removed.³ You can amend the return after renewal to reclaim those credits, but the sequence adds months to your refund.

How to Renew Before It Costs You

Renewal runs on Form W-7, the same form used to apply for a new ITIN. Check the “Renew an existing ITIN” box rather than the new-application box.⁴ You still submit identity and foreign-status documents.

If you are the primary filer renewing your own ITIN, you can send the W-7 on its own, without attaching a return. Spouses and dependents renewing so they can be claimed for a tax benefit have to include the return and the schedule tied to that benefit.¹

Timing matters. The IRS recommends submitting renewal applications in the fall for ITINs expiring December 31, before filing season begins. A renewal filed alongside your January or February return puts the return in limbo while the number is being reactivated. Standard mail processing runs about seven weeks; during filing season (January 15 through April 30) or from overseas, expect 9 to 11 weeks.⁵

Documents: Certified Yes, Notarized No

The IRS accepts 13 specific documents to establish identity and foreign status. A valid passport is the only single document that proves both. Without a passport, you submit two documents — one for identity and one for foreign status.⁶ A national ID card paired with a civil birth certificate is a common combination.

The distinction that sinks the most applications is between certified and notarized copies. A certified copy is one the original issuing agency has stamped as an exact copy (a government office reissuing a birth certificate, for instance). A notarized copy, where a notary witnesses your signature on a photocopy, is not accepted. The lone exception is for dependents of U.S. military personnel.⁷

Documents in a language other than English may need a certified translation. The IRS can request one at any point during processing, so having a translation ready before you submit avoids delays.⁸ Simple documents like birth certificates typically cost $20 to $30 per page to translate professionally.

Choosing How to Submit Documents

You have three options, and the trade-off is risk versus cost. Mailing originals to the IRS ITIN Operation in Austin is free, and the IRS returns the documents after processing, but sending a passport across borders carries obvious risk. A Certifying Acceptance Agent — an accountant, bank, or immigration services firm on the IRS-approved list — reviews your originals in person, certifies copies, and sends only the copies to the IRS, so your documents never leave your hands.⁹ Fees range from about $50 for a straightforward renewal to several hundred dollars for complex cases. Designated IRS Taxpayer Assistance Centers also authenticate documents on the spot, but not every center offers ITIN service, and appointments fill quickly during filing season.

Applying for a New ITIN

First-time applicants use the same Form W-7 and, in most cases, attach a completed federal tax return (usually Form 1040). A handful of exceptions apply, such as third-party withholding on passive income or claims for treaty benefits; the W-7 instructions list five specific exceptions.¹⁰

One detail worth getting right: on the tax return you attach to a new W-7, leave the Social Security number field blank. The IRS writes in your assigned ITIN and then processes the return.⁵

What Tax Credits an ITIN Actually Gets You

An ITIN lets you file a return and pay tax. It does not carry the same credit eligibility as a Social Security number, and the boundaries are strict.

Child Tax Credit: No

The Child Tax Credit and its refundable portion (the Additional Child Tax Credit) require the qualifying child to have a Social Security number issued before the return’s due date. This is written into the statute; an ITIN for the child does not qualify.¹¹¹²

Credit for Other Dependents: Yes

If your dependent has an ITIN, you may be able to claim the Credit for Other Dependents instead of the CTC. It is a $500 nonrefundable credit per qualifying dependent, who must be a resident alien or U.S. national.³ Many ITIN filers overlook it.

American Opportunity Tax Credit: Yes

The AOTC, worth up to $2,500 per qualifying student, is available to ITIN holders. The taxpayer, the spouse on a joint return, and the student must each have a valid SSN, ITIN, or Adoption Taxpayer Identification Number by the return’s due date.¹³ File Form 8863 with the return.

Earned Income Tax Credit: No

The EITC is closed to ITIN holders. The taxpayer, spouse (on a joint return), and any qualifying child must all have valid Social Security numbers.¹⁴ No exceptions.

Other Credits

ITIN holders can claim the Premium Tax Credit for Marketplace health coverage and the Child and Dependent Care Credit, assuming they meet the other requirements and attach the proper forms.³

If You Get a Social Security Number Later

Becoming eligible for an SSN — through a change in immigration status, for example — does not automatically retire your ITIN. You need to tell the IRS so your records consolidate under the new number. There is no dedicated form. Either visit a local IRS office or mail a letter to the IRS at Austin, TX 73301-0057 that includes your full name, mailing address, ITIN, a copy of your new Social Security card, and a copy of your CP 565 notice (the original ITIN assignment letter) if you have it.¹⁵

Once the IRS processes the request, it voids the ITIN and links prior returns to your SSN. Skip this step and you may not get credit for wages and withholding reported under the old ITIN, which can shrink a refund or trigger correspondence from the IRS. Stop using the ITIN as soon as the SSN is issued; using both is not permitted.

1
Internal Revenue Service. How to Renew an ITIN
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Internal Revenue Service. It’s Time Again for Folks to Renew Their ITINs
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Internal Revenue Service. Individual Taxpayer Identification Number
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Internal Revenue Service. Form W-7 – Application for IRS Individual Taxpayer Identification Number
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Internal Revenue Service. How to Apply for an ITIN
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Internal Revenue Service. ITIN Supporting Documents
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Internal Revenue Service. ITIN Documentation Frequently Asked Questions (FAQs)
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Internal Revenue Service. Instructions for Form W-7 (Rev. December 2024)
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Internal Revenue Service. ITIN Acceptance Agents
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Internal Revenue Service. Instructions for Form W-7
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Office of the Law Revision Counsel. 26 USC 24 – Child Tax Credit
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Internal Revenue Service. Instructions for Schedule 8812 (Form 1040) (2025)
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Internal Revenue Service. Education Credits – AOTC and LLC
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Internal Revenue Service. Who Qualifies for the Earned Income Tax Credit (EITC)
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Internal Revenue Service. Additional ITIN Information