IRS Releases Contingency Plan Amid Government Shutdown

Yesterday, the IRS released their FY 2026 Lapsed Appropriations Contingency Plan in the event of a government shutdown. According to the current plan, all IRS employees would continue working for the first five business days of a lapse of appropriations.

Government shutdowns pose significant issues to the tax administration system. Because of these concerns, the AICPA submitted a comment letter requesting the IRS issue a plan allowing all IRS employees to continue working during a shutdown—or at least to retain more employees than in prior shutdowns—and also raised the impact that the 2019 shutdown had on the tax community, including: 

• Issuance of automated IRS collection notices without any ability to resolve
• Suspension of audit, examination, and appeals activities
• Challenges with online account access and electronic payments
• Substantial wait times when IRS phone services resumed

Filing Deadlines Will Likely Not Change

Historically, filing deadlines have not been adjusted due to a government shutdown, and this is not expected to change. Taxpayers who have filed with a valid extension for the 2024 tax year must still meet the October 15, 2025, deadline. 

Similarly, payments or collection activities will likely not be adjusted—CPAs are encouraged to instruct clients to continue to make scheduled payments, including those that are part of installment agreements. Employers must also continue to deposit federal income tax withholdings, along with Social Security and Medicare taxes, according to the regular deposit schedule.