Essentially all taxing jurisdictions in the United States now provide taxpayers with the ability to make payments electronically. 

The IRS will stop issuing refund checks on September 30, 2025. Here’s what you need to know.

Earlier this year, President Donald Trump signed Executive Order 14247, entitled “Modernizing Payments to and from America’s Bank Account,” which essentially requires all payments made to and from the federal government to be done so electronically, with limited exceptions. Not only does this affect the IRS, but all government agencies, including the Social Security Administration, the Department of Labor, the Defense Finance and Accounting Service and the Office of Personnel Management. The full text of the order is available on the Federal Register.

Specific Provisions

The order states that beginning September 30, 2025, the federal government will no longer issue paper checks, with limited exceptions. For taxpayers expecting refunds on their extended 2024 tax returns, we recommend that any tax return filed after September 30 include banking information to avoid delays in receiving the expected refund. Depending on the taxpayer’s circumstances, as well as capacity within the IRS, it is entirely possible for tax returns already filed and in the “processing” status at the time this executive order goes into effect to be affected so that any refund requested will likely be held after the return has been processed, with additional correspondence and procedures needed to set up an electronic refund. 

Additionally, the order also states that payments made to the federal government must be made electronically “as soon as practicable,” with limited exceptions. Unlike the refund provision, which contained a specific cut-off date, this electronic payment mandate does not provide such specificity. This ambiguity leaves room for interpretation. One could argue that for many taxpayers, making such payments online is already practicable, and therefore all payments made after the date this executive order was signed must be made electronically. Taxpayers can easily make payments to the IRS on the payments section of the IRS website.

Further, for the electronic payment mandate, it is unclear whether the IRS will stop accepting payments in the form of checks entirely. If this does happen, a taxpayer who mails in a check that the IRS does not accept may be subject to interest and penalties if the taxpayer is not given an opportunity to timely cure the issue, resulting in a late payment assessment by the IRS. It is also unknown whether the IRS will impose a penalty on individual taxpayers who opt to still pay via paper check. As an example, for the past several years, the Pennsylvania Department of Revenue has required that all payments equal to or greater than $15,000 be made electronically and imposes a maximum penalty of $500 if such payment is made by check. California imposed a similar requirement. Perhaps the IRS will implement a similar type of penalty for payments that are required to be made electronically.

Implementation Details Remain Forthcoming

We expect forthcoming guidance and regulations from the Treasury Department. Agency heads were required to submit a “compliance plan” to the director of the Office of Management and Budget within 90 days of the date of this order, detailing their strategy for eliminating paper-based transactions. Though that deadline of June 23, 2025, has passed, there is no public record confirming whether agency heads actually submitted such plans. The absence of public announcements or documentation suggests that either the plans were submitted without public coverage or are pending acknowledgement. 

In addition to agency input, public comments were also solicited in order to guide the Treasury’s implementation of this executive order. Many public comments focused on taxpayers without a bank account and/or internet access. While these are valid concerns, it is important to note that one of the exceptions specifically listed in the executive order is for individuals who do not have access to banking services or electronic payment systems. 

After consideration of the public comments and agency strategies, the Secretary of the Treasury is required to submit an implementation report to the president within 180 days of the order (i.e., by September 21, 2025). While this date is still a few weeks away, no implementation report from the Treasury Secretary has been released publicly as of this point.

TAG’s Perspective

We recognize that many taxpayers are reluctant to provide their bank information to the IRS and would prefer to still mail and receive checks. While this seems to be a common concern, it is worth noting that the essential information required for electronic transfers, such as routing and account numbers, is already printed on every paper check. Thus, the underlying bank information that taxpayers are justifiably concerned about protecting is equally present in both paper and electronic payment transactions. So, for taxpayers who need to make payments to the IRS—either quarterly estimates or for a balance due on their finalized tax return—their bank information will inevitably be provided to the IRS one way or another. Ironically, mailing paper checks also introduces the added risk of physical theft or loss while in transit, which could make it even less secure than a properly managed electronic transfer.

While the ability to make electronic payments to the IRS has existed since the 1990s, this federal electronic payment mandate was inevitable and has been anticipated as there are many states and localities which have adopted similar mandates in recent years. As we serve clients in all 50 states, we have been encouraging our clients to make payments electronically for years, including payments made to states and localities. Essentially all taxing jurisdictions in the United States now provide taxpayers with the ability to make payments electronically. For those states that have not yet adopted electronic payment mandates, we expect them to follow suit in the near future. 

Given the fact that it is unclear what it means for it to be “practicable” to make payments electronically, and since there has been no further guidance published on the matter at this time, we recommend that taxpayers make all payments electronically to avoid any unnecessary compliance issues. As stated plainly in the text of this order, the purpose of this mandate is to promote operational efficiency. We largely agree with this sentiment, and a myriad of issues can be avoided by making payments electronically, including payments being applied to the wrong taxpayer’s account, payments being applied to the wrong tax year, assessment of interest and penalties on late payment due to late receipt of a timely mailed check without a certified mail receipt, and the assessment of interest and penalties on late payment because the check was either lost in the mail or stolen.

For those taxpayers with access to banking services and the internet, we recommend you confirm your bank account information in a secure manner and contact us to discuss the options available to you for making electronic payments to the IRS.

For More Information

If you would like more information about this topic or your own unique situation, please contact John I. Frederick, Michael A. Gillen or any of the practitioners in the Tax Accounting Group. For information about other pertinent tax topics, please visit our publications page.

Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.