A federal government shutdown always creates uncertainty, and CPAs find themselves on the front line—helping clients navigate disrupted services, unclear deadlines, and communication delays.

IRS Contingency Plan Released

Earlier today, the IRS released its FY 2026 Lapsed Appropriations Contingency Plan. Of note, the plan states that all IRS employees would continue working during a shutdown—effective for the first five business days of a lapse in appropriations.

This represents a shift from prior shutdowns when IRS operations were severely curtailed, leading to widespread challenges for both taxpayers and practitioners.

Why CPAs Should Care

As many of us remember, the 2019 government shutdown had significant ripple effects across the tax administration system:

• Automated IRS collection notices were issued with no available staff to resolve them.
• Audits, examinations, and appeals activities were suspended, leaving taxpayers and CPAs in limbo.
• Online account access and electronic payments became more difficult to navigate.
• Phone service wait times were substantial once the IRS reopened.

These disruptions create compliance risks for clients and operational headaches for CPAs. Even short shutdowns can add layers of confusion during an already complex filing and compliance landscape.

AICPA Advocacy in Action

Earlier this week, the AICPA submitted a comment letter urging the IRS to ensure continuity of operations in the event of a shutdown. Specifically, the AICPA requested that:

• All IRS employees continue working throughout any shutdown, or at minimum,
• The IRS retain more employees than in prior years to reduce disruption.

The letter also emphasized the real harm caused during the 2019 shutdown and outlined why the profession cannot afford a repeat.

What CPAs Can Do Now

• Stay Informed: Monitor IRS and AICPA communications for the latest updates.
• Prepare Clients: Remind clients of potential delays in notices, exams, or refund processing.
• Document Everything: Keep thorough records of interactions and attempted filings in case issues arise.
• Lean on COCPA & AICPA Resources: We’ll continue to monitor the situation and share updates as they develop.

Bottom line: A government shutdown may not stop your work, but it can complicate it. Stay proactive, keep your clients informed, and rely on professional resources to guide you through any disruptions.