ERC claims for late 2021 filed after January 2024 are barred

The bar applies only to ERC claims for the third and fourth quarters of 2021 that were filed after January 31, 2024. A claim counts as timely if it was properly mailed with a postmark, or submitted, by that date. Claims for other quarters, and Q3 or Q4 2021 claims filed on time, are not limited by this provision.

From July 4, 2025, the IRS cannot allow or refund a barred claim. If a late claim was already paid or credited before that date, this provision does not claw it back, though other compliance work may still lead to an adjustment.

• Pull the filing date and proof of mailing for each open claim.
• If a Letter 105-C arrives and the claim was in fact filed by January 31, 2024, the client can appeal to the IRS Independent Office of Appeals.
• An amended return filed later that withdraws an earlier, timely claim is still processed.
• If the disallowed ERC sits on a return with other items, the IRS can still process the rest of that return.

Many clients booked an ERC receivable when they filed. Where the claim is now barred, write the receivable off and revisit any wage deduction that was reduced for the credit, so the balance sheet stops showing money that will not arrive.