Tax professionals navigating the 2026 filing season are doing so against a backdrop of IRS leadership uncertainty, workforce instability, and renewed scrutiny of unregulated tax preparers. Here is what matters most for your practice right now.
IRS Leadership Remains in Flux
The IRS confirmed that Treasury Secretary Scott Bessent's term as acting commissioner under the Federal Vacancies Reform Act expired on March 6, 2026, though he continues to oversee the agency through his role at Treasury. Frank Bisignano now holds the newly created CEO position at the IRS while simultaneously serving as commissioner of the Social Security Administration, a dual role that has drawn criticism from Senate Democrats who argue the CEO title is an unauthorized workaround to avoid Senate confirmation.
The agency recorded seven commissioners and acting commissioners through August 2025 alone. Bisignano announced additional leadership changes in January as the filing season launched, adding to organizational uncertainty. Despite this, the IRS reports that the 2026 filing season opened on schedule January 26, and that 2025 saw more than 165 million individual returns processed and 17 million phone calls answered.
Technology and Staffing Gaps Are Real
A Government Accountability Office report found that in December 2025, an internal IRS document warned that critical technology systems would not be ready for the 2026 filing season and that key functions would enter the season undertrained or understaffed. The GAO recommended the IRS address its correspondence backlog, update its strategic workforce plan, and build an implementation team to manage ongoing reforms. The IRS neither agreed nor disagreed with those recommendations.
For practitioners, this means correspondence delays, slower response times on complex matters, and potential processing errors should be anticipated. Building extra lead time into resolution work and client communication is a practical safeguard this season. Utilize the practitioner hotline and taxpayer advocacy center for best results when a phone call is the only fit to address issues.
Uncredentialed Preparers Under the Microscope
A mystery shopping study from the Center for Taxpayer Rights found widespread errors and incompetence among non-credentialed paid preparers across six states. Testers found preparers routinely misapplied filing status rules, incorrectly claimed the Earned Income Tax Credit and Child Tax Credit, and failed to properly report sole proprietorship income including unreported cash. All three test scenarios produced incorrect refund amounts.
Approximately 56% of the more than 684,000 IRS-registered preparers hold no credential, and the actual number of unregulated preparers is likely higher due to ghost preparers who never sign returns. Senate Finance Committee leaders introduced the bipartisan Taxpayer Assistance and Service Act to establish minimum competency standards and penalties for paid preparers.
For credentialed practitioners, this environment is both a risk and an opportunity. Clients who have used uncredentialed preparers in prior years may arrive with carryover errors that require correction. It also reinforces the value of your credential in client conversations.
The filing season is moving forward despite significant structural headwinds at the IRS. Staying ahead of delays, verifying prior year returns for new clients, and monitoring legislative developments on preparer regulation are the most actionable priorities right now.
Dr. Christine Gervais is a licensed CPA, using her skills to help businesses grow and achieve their fullest potential. Christine has a Master’s degree in accounting from Southern New Hampshire University in addition to holding her CPA license for over a decade. Notably, Christine is a nationally recognized speaker providing education to other CPAs on how to best serve clients as well as instruction on a wide variety of topics for business owners on how to maximize success. Christine prides herself on the value she can bring to clients with her extensive tax knowledge and provides strategic, forward-thinking financial strategies to help clients grow. When not behind her desk, you can find Christine spending quality time with her daughter and stepson or tending to the family’s excessively loved farm animals.
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