# Agency Information Collection Activities: IRS Seeks Comments on Contractor Disclosure Burden > The IRS published a Paperwork Reduction Act comment request on July 27, 2026, targeting the disclosure of return information under written contractor agreements for tax administration. Small and mid-size CPA firms that serve government contractors, nonprofits, or multi-entity clients with IRS data-sharing agreements have a narrow window to comment. Here is the operational breakdown your firm needs. **Source:** https://taxscout.ai/blog/agency-information-collection-activities-irs-seeks-comments-on-contractor-disclo **Published:** 2026-07-27 **Updated:** 2026-07-27T18:08:35.843Z **Author:** TaxScout Team **Category:** news **Tags:** IRS Compliance, Tax Forms, CPA Practice Management, Document Management, Professional Liability --- On July 27, 2026, the IRS posted a new agency information collection activities notice in the Federal Register, inviting public comments on the paperwork burden tied to disclosing tax returns and return information under written contracts or agreements for acquiring property or services for tax administration purposes. The underlying authority is [IRC § 6103(n)](https://www.irs.gov/privacy-disclosure/tax-code-regulations-and-official-guidance), which permits the IRS to share otherwise confidential return data with contractors who support tax administration functions — but only under strict written agreements. Most coverage will paste the Federal Register headline and stop there. For [CPA firm](/glossary/cpa-firm) owners, the relevant questions are narrower: does this affect your engagement agreements, your clients' contractor relationships with the IRS, or the document-handling obligations you manage on their behalf? The short answer: if you advise government contractors, large nonprofits with IRS compliance arrangements, or multi-entity clients operating under IRS data agreements, this notice is worth 15 minutes of your time before the comment window closes. Understanding agency information collection activities helps CPA firm owners quickly identify which notices actually affect their practice versus those they can safely file away. The primary source is the [Federal Register notice published 2026-07-27](https://www.federalregister.gov/documents/2026/07/27/2026-15082/agency-information-collection-activities-comment-request-on-the-burden-related-to-the-disclosure-of). The IRS is specifically asking whether the estimated burden is accurate, whether the collection is necessary, and whether there are ways to reduce compliance costs — standard Paperwork Reduction Act language, but the comment window gives your firm a direct line to influence how IRS contractor agreements are structured going forward. For firms evaluating their agency information collection activities approach, this trade-off compounds over time. ## What the IRS Is Actually Asking The [Paperwork Reduction Act of 1995](https://www.law.cornell.edu/uscode/text/44/3501) requires federal agencies to justify every information collection requirement imposed on the public and to seek public input before renewing or modifying those requirements. This notice covers the specific collection associated with written contracts between the IRS and third-party vendors or contractors who receive return information — social security numbers, income data, filing history — to perform tax administration work. Each of these factors directly shapes how agency information collection activities plays out in practice. The IRS is asking three standard PRA questions: (1) Is this collection necessary for proper tax administration? (2) Is the agency's burden estimate — the hours and cost firms and contractors spend complying with the disclosure agreement requirements — accurate? (3) Are there ways to enhance the quality or reduce the burden of the collection? Comments are due 60 days from the July 27, 2026 publication date, placing the deadline around September 25, 2026. Understanding agency information collection activities in this context is what separates firms that scale from those that stall. For CPA firm owners, the practical implication is not that your firm must file anything in response to this notice. Rather, if your clients have written agreements with the IRS under IRC § 6103(n) — or if your firm itself has such an arrangement as an IRS-approved vendor — you may want to review whether the current burden estimate reflects your actual compliance costs and submit a comment if it does not. For broader context on related IRS regulatory updates affecting CPA practices, see our [other news resources](/blog/category/news). ![TaxScout review interface with AI research agents and client context](/screenshots/review-advise.webp) *Review with AI assist — 9 agents answer questions with full client context* **Which Entity Types and Client Segments Are Affected** --- **Tired of manual workflows slowing your firm down?** See how TaxScout handles this with AI-powered automation. [→ Book a 15-Min Demo](/demo) --- IRC § 6103(n) disclosure agreements are not common for individual 1040 filers. The entities most likely to have written contractor agreements with the IRS that trigger this collection include: Government contractors and IT vendors that process IRS data on behalf of the agency — these entities sign formal IRC § 6103(n) agreements and are directly subject to the paperwork requirements this notice covers. If you serve clients in federal contracting, defense, or government IT, ask whether they hold such agreements. Large nonprofits and tax-exempt organizations that have entered compliance or data-sharing arrangements with the IRS as part of audit resolution or special programs. See our [nonprofit audit preparation guide](/blog/nonprofit-audit-preparation-guide) for related compliance considerations. S-corps and partnerships in the government services sector may also be indirectly affected if their operating entities are parties to IRS contractor agreements. Standard 1040 clients, small business 1040-[Schedule C](/glossary/schedule-c) filers, and typical S-corp or partnership returns are not directly affected by this collection. The disclosure burden here sits with entities that receive IRS return information under formal written agreements — not with taxpayers generally. --- **Tracking IRS regulatory notices manually while managing a full [client pipeline](/glossary/client-pipeline)?** TaxScout's AI research agents monitor IRS, Treasury, and Federal Register updates in real time — so your team stays current without the daily manual scan. [→ See How It Works](/features) --- ## What to Do This Week: A Four-Step Action List **Step 1: Identify affected clients.** Pull your client list and flag any entity that is a federal contractor, IRS-approved vendor, or large nonprofit with a formal IRS data-sharing arrangement. If you are unsure, check engagement letters and prior-year correspondence for references to IRC § 6103(n) or written disclosure agreements. **Step 2: Review existing contractor agreements.** For flagged clients, locate any written contracts or agreements under which the IRS shares return information. Confirm the agreement is current, that the client's data-handling procedures comply with the agreement's terms, and that your firm's document management practices align. TaxScout's [file management features](/features/file-management) and [security infrastructure](/features/security) — including AES-256-GCM encrypted SSN vault and 7-role RBAC — support the secure handling requirements these agreements typically impose. **Step 3: Assess whether to submit a comment.** If your firm or a client has direct experience with the burden of maintaining IRC § 6103(n) disclosure agreements, the PRA comment process is a legitimate channel to tell the IRS whether their burden estimate is accurate. Comments should be specific: cite the hours your team spends on agreement maintenance, audits, or recordkeeping. Submit via regulations.gov by approximately September 25, 2026, referencing the Federal Register docket number 2026-15082. **Step 4: Update your intake and engagement documentation.** If any client's work involves IRS contractor disclosure obligations, ensure your [smart intake engine](/features/ai-intake) captures that context and your engagement letters reflect the additional compliance scope. This is also a good moment to verify that e-signature workflows for engagement letters are current — see our guide to [e-signature compliance for accountants](/blog/electronic-signatures-accountants-compliance) for best practices. ![TaxScout client detail view with document organizer and pipeline stages](/screenshots/pipeline2.webp) *Every client gets organized documents, status tracking, and a complete history* ![TaxScout pipeline management kanban board showing tax returns across stages](/screenshots/pipeline.webp) *Track every return from intake to filed with drag-and-drop pipeline management* ## Why Agency Information Collection Activities Notices Matter for CPA Firms Most PRA notices generate little practitioner attention, and this one carries a low priority signal for the average tax practice. But agency information collection activities notices are the mechanism through which the IRS calibrates the real-world cost of compliance — and when CPAs fail to engage, the IRS defaults to burden estimates that often undercount actual firm hours. The [IRS Taxpayer Advocate's annual report](https://www.irs.gov/taxpayer-advocate) consistently flags the aggregate paperwork burden on taxpayers and preparers as a systemic problem. PRA comment periods are one of the few formal opportunities practitioners have to put documented evidence in front of the agency before an information collection is locked in for another three years. For firms managing document workflows at scale, the indirect benefit of engaging with these notices is also reputational: clients in regulated industries — federal contractors, large nonprofits, multi-state partnerships — value advisors who track the full regulatory environment, not just filing deadlines. Pairing that advisory posture with efficient [document management](/blog/cpa-firm-document-management-software-guide) and [AI document extraction](/features/ai-document-extraction) capabilities positions your firm as a high-value compliance partner, not just a return preparer. For related IRS reporting threshold changes affecting a broader client base, see our earlier coverage of the [proposed 1099 reporting threshold increases](/blog/irs-proposes-higher-1099-reporting-thresholds-what-cpa-firms-must-do-now). ## Key Dates and Source Reference **Published:** July 27, 2026 in the Federal Register. **Comment deadline:** Approximately September 25, 2026 (60 days from publication). Submit comments at regulations.gov referencing docket 2026-15082. **Primary source:** [Agency Information Collection Activities: Comment Request on the Burden Related to the Disclosure of Returns and Return Information in Connection With Written Contracts or Agreements for the Acquisition of Property or Services for Tax Administration Purposes](https://www.federalregister.gov/documents/2026/07/27/2026-15082/agency-information-collection-activities-comment-request-on-the-burden-related-to-the-disclosure-of) — Federal Register, July 27, 2026. **Authorizing statute:** [IRC § 6103(n)](https://www.law.cornell.edu/uscode/text/26/6103) via [law.cornell.edu](https://www.law.cornell.edu/uscode/text/26/6103). Disclosure rules for return information shared with contractors are also summarized in [IRS Publication 1075](https://www.irs.gov/pub/irs-pdf/p1075.pdf), which governs federal, state, and local agency safeguards for tax data. **Affected filing types:** Not applicable to standard 1040, Schedule C, S-corp (1120-S), or partnership (1065) filings directly. Relevant to entities with formal IRS contractor agreements under IRC § 6103(n) — primarily federal contractors, IRS-approved vendors, and select large nonprofits. --- **Spending hours tracking IRS notices that may not even apply to your client base?** TaxScout's 9 AI research agents screen regulatory updates against your actual client portfolio — surfacing only what matters to your firm, automatically. [→ Book a Demo](/demo) --- ![TaxScout AI preparation workflow showing document classification and extraction](/screenshots/ai-prepares.webp) *AI classifies, extracts, and validates every document automatically*