IRS CP05 notice: why your refund is on hold and how long it lasts

What the IRS CP05 notice means

The IRS CP05 notice is a hold notice, not a bill and not an audit. The IRS is saying it wants more time to check one or more items on your return against its own records: wages and other income, federal income tax withheld, refundable credits, or business income. Until it finishes, the refund stays on hold.

The notice does not ask you for anything if you filed the return. That is the main difference between a CP05 and the letters around it. Your only job is to wait out the stated period and keep an eye on your mail.

A CP05 on its own is not a finding that anything on the return is wrong. It means the IRS has not finished checking. For the full list of refund holds, see tax refund delayed.

IRS CP05 meaning compared with similar notices

People often confuse the CP05 with notices that do require a reply. Check the code in the corner of the page and match it here before deciding to wait.

If yours says CP05A, the rules change: the IRS wants at least 3 pay stubs or an employer letter showing wages and withholding, and asks you to allow 60 days from the date you provide them. Our CP05A notice page covers what to send.

How long a CP05 review takes

The IRS asks you to allow up to 60 days from the date printed on the notice, and not to call before then. Count from the notice date, not from the day it arrived or the day you filed.

A worked example: a CP05 dated March 16 reaches you on March 23. Sixty days from the notice date is May 15. Until then, a call is unlikely to get you anything the notice has not already said.

Some reviews take longer. The Taxpayer Advocate Service puts IRS reviews at 45 to 180 days depending on how complex the issues are. If the IRS needs something from you along the way, it sends a separate notice or letter that says exactly what.

Your account transcript may show a TC 570 during the review, meaning a hold on the refund. A TC 571 or a TC 846 later signals release. See transcript code 570 for how to read it.

Do I need to respond to an IRS CP05 letter?

Not if you filed the return. The IRS says no action is needed in that case. Replying anyway, filing an amended return, or sending documents nobody asked for does not speed up the review.

What you can do is prepare. If the review turns into a request for proof, you will want these ready:

• Every Form W-2 and Form 1099 for the year
• Year-end pay stubs that show gross pay and federal tax withheld
• Records for any business income and expenses reported on Schedule C
• Support for refundable credits, such as proof a child lived with you
• A copy of the return exactly as filed

Check that the notice is real before you act on anything it says. Compare it with the IRS's own description of the CP05 on IRS.gov or look for it in your IRS online account. Our page on IRS verification letter scams lists the warning signs.

If you did not file the return

A CP05 about a return you never filed is a sign that someone may have used your Social Security number. The IRS directs you to complete Form 14039, Identity Theft Affidavit, and mail the signed form to the address shown on your CP05.

1. Confirm you did not file, and that no preparer or family member filed for you.
2. Download and complete Form 14039 from IRS.gov.
3. Sign it and mail it to the address printed on the CP05.
4. Keep copies of everything and note the mailing date.
5. Consider requesting an IP PIN through your IRS online account so future returns filed under your number need a 6-digit code.

What happens after the CP05 review

When the IRS finishes, the review ends in one of a few ways. Knowing them helps you read the next piece of mail quickly.

• Refund released as filed. Status tools move to approved and then sent. If more than 45 days passed after the due date or the date the IRS received your return, whichever is later, the refund generally includes interest.
• Refund changed. The IRS sends a CP12 explaining the adjustment; if you agree, the refund follows in about 4 to 6 weeks. See the CP12 notice page.
• Documents requested. A follow-up letter asks for proof and restarts the clock from your reply.
• Refund used for a debt. Part or all of the refund may go to a federal tax debt or another agency, with a separate notice.

If your CP05 arrived before mid-February on a return with the EITC or ACTC, the PATH Act refund hold also applies, and the refund cannot go out before February 15 even if the review ends sooner.