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Proficur Insights September 15, 2026

17,300 ERC Claims Are Still Outstanding. Here’s What’s Holding Them Up.

17,300 ERC Claims Are Still Outstanding. Here’s What’s Holding Them Up.
17,300 ERC Claims Are Still Outstanding. Here’s What’s Holding Them Up - Proficur Insights

The Employee Retention Credit stopped accepting new claims years ago. It has not, however, finished being a live issue for the businesses still waiting on one.

According to the IRS’s own published tracker, as of the week ending August 1, 2026, approximately 17,300 ERC claims remained open across several stages.

Where Things Actually Stand

01
2,300 claims under review
02
2,900 pending payment or disallowance
03
4,400 under audit, 6,100 awaiting review of disallowance responses, and 1,600 with the Independent Office of Appeals

A February 2026 Government Accountability Office report stated that, according to IRS officials, the IRS had closed all remaining ERC claims other than those under examination or appeal by December 31, 2025. That means the claims still outstanding are largely in examination, disallowance-response review, or Appeals rather than a normal processing queue.

Why Audits, Not Payments, Are the Default Now

The IRS has made clear that it is closely reviewing ERC claims because of the high volume of improper claims. Claims remaining in the pipeline can be subject to examination, disallowance, or Appeals, making documentation and support for the original eligibility position increasingly important.

The Extended Audit Window

Statute of Limitations

The One Big Beautiful Bill Act: Extended the IRS assessment period for certain third- and fourth-quarter 2021 ERC claims to six years. As a result, affected claims can remain subject to IRS assessment well beyond the previous limitation period.

Separately, OBBBA introduced new penalties targeting the promoters who aggressively marketed ERC claims to businesses that ultimately didn’t qualify.

WHY THIS MATTERS TODAY

A client who filed an ERC claim years ago and hasn’t heard anything shouldn’t assume “no news” means the claim is quietly working its way toward payment. It’s just as likely sitting in an audit queue, and the six-year assessment window means even paid claims can still be revisited.

What to Check for Clients With Outstanding Claims

Whether the claim relates to Q3/Q4 2021 and is subject to the extended six-year assessment period
Whether documentation supporting the original eligibility test (gross receipts decline vs. government-order suspension) is still readily available
Whether a disallowance letter was received and the response deadline has been tracked
Need Offshore Accounting Support? Partner with dedicated offshore specialists to manage audit documentation trails, claim status tracking, and appeal deadlines.

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