The IRS Rebuilt Its Identity Theft Defense Program: Why That Matters If You Have an Unfiled Return

On June 8, 2026, the IRS and its Security Summit partners announced a complete restructuring of the public-private anti-fraud system that guards the U.S. tax system, issuing notice IR-2026-75 to detail the changes. Then, on September 16, 2026, the IRS closed out its summer awareness series with IR-2026-111, urging continued vigilance as threats keep evolving. If you have unfiled returns, an open tax balance, or outstanding IRS notices, this rebuild affects you in ways that are worth understanding before you take your next step.

What the Security Summit Is and Why It Was Rebuilt

Formed in 2015, the Security Summit is a public-private partnership made up of the IRS, state tax administrators, tax software companies, tax professionals, and the larger tax community, with the goal of safeguarding taxpayers from various threats from fraudsters. Over the years, that partnership racked up real results. Since its inception, the work of the Security Summit has helped protect millions of taxpayers against identity theft and prevented billions of dollars from being wrongly paid out to fraudsters.

So why rebuild something that was working? Because criminals adapted. As the IRS and Summit partners have strengthened their systems, identity thieves have increasingly shifted to stealing underlying tax and financial information from taxpayers, businesses, and tax professionals to file authentic-looking fraudulent returns, hoping to evade traditional safeguards. The old structure was no longer built for the threat it was facing.

“Identity thieves continue to evolve, and so must we,” said IRS Return Integrity and Compliance Services Director Jim Clifford. “By aligning our work across every stage of the tax lifecycle and strengthening collaboration with partners, including the payroll industry, we are better positioned to stop fraud earlier and protect taxpayers and the nation’s revenue.”

The Five New Workstreams: A Plain-English Breakdown

The updated framework establishes five work groups focused on pre-filing, forecasting, preventing, detecting, and responding, placing greater emphasis on payroll partners targeted by cybercriminals. Here is what each one actually does.

• Pre-filing. Early identification of potentially fraudulent information returns and suspicious behavior within payroll and tax administration processes that could enable identity theft or fraud, including closer coordination with payroll providers.
• Forecasting. Identification of emerging schemes and proactive anticipation of threats before they are widely exploited.
• Preventing. Implementation of proactive measures and tools designed to reduce opportunities for fraud, including strengthening safeguards across payroll systems and data exchanges.
• Detecting and reporting. Real-time identification of fraud indicators and enhanced intelligence-sharing among partners, including payroll industry stakeholders.
• Responding. Deployment of technical controls and coordinated operational responses to security incidents.

The Security Summit also continues to use the Coalition Against Scam and Scheme Threats, which focuses on rapid assessment and response to emerging, time-sensitive risks.

The Scale of the Problem, by the Numbers

This restructuring did not happen in a vacuum. The identity theft problem hitting the tax system is enormous. The IRS stopped $7 billion in fraudulent refunds in calendar years 2024 and 2025, and during that two-year period selected about 7.5 million individual tax returns through its identity theft filters. Those filters screen returns before refunds are issued and use characteristics of known and emerging fraud schemes to flag suspicious filings.

The scale of fraud is serious, but so are the delays that come with it. In 2025, it took an average of 20 months for identity theft cases to get resolved, according to the National Taxpayer Advocate. Extended case wait times mean delays for refunds for victims. If your return gets caught in that process because a thief filed under your Social Security number before you did, resolving it takes real time and real effort.

Why People with Unfiled Returns Are Especially Vulnerable

The new framework targets fraud at every stage of the tax lifecycle. That matters most to people whose returns are not in the system yet. If you have not filed for one or more years, there is nothing on record to signal that a return filed in your name is fraudulent. A thief can file first using your name and Social Security number, collect a refund, and disappear, leaving you to spend months proving the return was not yours.

People with open tax balances face a different but related risk. Warning signs the IRS flags include receiving authentication letters such as 5071C, 4883C, or 5747C even though you did not file a return, a notice that an IRS Online Account was created in your name without your authorization, tax transcripts you did not request, and tax refunds even though you did not file a return. Any of these signals on an account that already has a balance or missing returns can make an already complicated situation far harder to untangle.

As the IRS and Summit partners have strengthened their systems, identity thieves have increasingly shifted to stealing underlying tax and financial information from taxpayers, businesses, and tax professionals to file authentic-looking fraudulent returns, hoping to evade traditional safeguards. The more your tax situation looks like a blank slate to the IRS, the more room a thief has to work.

Steps You Can Take Right Now to Protect Yourself

Get an Identity Protection PIN

The IRS IP PIN is a six-digit code that stops criminals from filing fraudulent tax returns using your Social Security number or ITIN. Anyone who has a Social Security number or an ITIN and is able to verify their identity is eligible to enroll in the IP PIN program, and parents and legal guardians can also request an IP PIN for dependents.

The fastest way to receive an IP PIN is to request one through your online account, in the IP PIN section of your profile page. If you do not already have an account on IRS.gov, you will need to register to validate your identity. An IP PIN must be used when filing any federal tax returns during the year, including prior-year returns. That last detail is important: if you are filing late returns for past years, the IP PIN covers those too.

Watch for warning letters

If the IRS mails you a letter numbered 5071C, 4883C, or 5747C, respond to it. These are identity verification requests, not collection notices, and ignoring them stalls any return that is waiting to process. Similarly, if you receive IRS notices about an account you did not open or transcripts you did not request, treat them as red flags that require immediate action.

File your missing returns as soon as possible

Every year an unfiled return sits unresolved, it is a year a thief can exploit. The new pre-filing workstream is specifically designed to catch suspicious activity on information returns and in payroll data before a fraudulent return is accepted. But it cannot protect a gap that was never filled. Getting current on your filing is the single most direct way to close the window that identity thieves use.

How Clear Start Tax Can Help

If you are behind on filing, carrying a tax balance, or dealing with IRS notices you do not fully understand, the stakes just got higher. The IRS now has more tools than ever to detect fraud, but those same tools can flag legitimate taxpayers who are behind, suspend returns, and extend the timeline for resolving your account.

Clear Start Tax works with individuals and businesses who owe the IRS or are behind on filing. The firm helps clients understand their options, depending on their circumstances, which may include currently-not-collectible status, installment agreements, offers in compromise, penalty abatement, and other IRS resolution programs. No two situations are the same, and outcomes vary, but doing nothing is never the right answer, especially now that the system watching for fraud is more sophisticated than it has ever been.

The right first step is a consultation. Knowing where you stand, exactly what is owed, and what options could be available to you puts you in a far stronger position than staying in the dark. Contact Clear Start Tax to speak with a tax resolution specialist about your specific situation.