Understand PATH Act Refund Delays
Claiming the Earned Income Tax Credit (EITC) or Additional Child Tax Credit (ACTC) and stuck on a PATH message? Use this hub to understand why your refund is delayed, how long the hold usually lasts, and what steps to take next.
What Is the PATH Act?
The Protecting Americans from Tax Hikes (PATH) Act is a federal law that made the EITC and ACTC permanent while adding anti-fraud rules that change refund timing.
- Requires IRS to hold refunds with EITC/ACTC until at least Feb. 15
- Gives IRS time to match W-2/1099 info and prevent fraud
- Includes rules requiring some ITIN holders to renew their ITIN
Who Is Affected by PATH?
The PATH Act affects taxpayers who claim the EITC or ACTC. If these credits appear on your return, your entire refund is held — not just the credit portion.
- Applies even if you file on opening day
- Applies to e-file, paper, and preparer-filed returns
- Refund cannot be issued before Feb. 15 by law
How the PATH Act Affects Your Refund
If you claim the Earned Income Tax Credit (EITC) or Additional Child Tax Credit (ACTC), your refund is subject to a mandatory hold. Here is what that really means in practice.
Mandatory Refund Hold Until At Least February 15
By law, the IRS cannot issue any refund that includes EITC or ACTC before February 15, even if you filed early and your return was accepted quickly.
- Hold applies to the entire refund, not just the credits
- Early filing does not bypass PATH, but still helps prevent identity theft
- Expect most PATH refunds to fund after the hold window plus normal processing time
Families & Workers Claiming EITC or ACTC
PATH primarily impacts moderate- and lower-income workers and families who qualify for refundable credits like the EITC and ACTC.
- Millions of returns each year fall under PATH rules
- If you are not claiming EITC or ACTC, PATH generally does not apply
- Your refund can still be delayed for other reasons (review, identity verification, offsets)
ITIN Expiration & Renewal Requirements
The PATH Act also requires certain Individual Taxpayer Identification Numbers (ITINs) to be renewed if they have not been used on a tax return for three consecutive years.
- Expired ITINs can block credits and delay refunds
- Renew your ITIN before filing to avoid last-minute issues
- See IRS guidance on ITIN renewal for current rules
“Where’s My Refund?” Messages During PATH Hold
The IRS “Where’s My Refund?” tool will often show standard messages during the PATH Act hold. Use this table to match what you see online with what it usually means.
Common Refund Status Messages & Meanings
| Message | What It Usually Means |
|---|---|
| “Return Received” | The IRS has accepted your return and is processing it, but has not yet approved your refund. During the PATH window, many EITC/ACTC filers stay on this message until after the hold lifts. |
| “Refund Approved” | The IRS has finished processing your return and approved your refund. If your return includes EITC/ACTC, the refund still cannot be issued until after the PATH hold period. |
| “Refund Sent” | Your refund has a scheduled issue date and is being sent to your bank or mailed as a check. At this point PATH no longer applies — any remaining delay is usually banking or mailing time. |
| Message referencing PATH or “delayed by law” | The IRS is holding your refund under PATH rules because your return includes EITC or ACTC. This hold lasts until at least February 15 each year. |
| “Further Review” or “Additional Information Needed” | Your return requires extra review beyond the standard PATH hold, often for income verification, dependent issues, or identity confirmation. This can extend your refund timeline past mid-February. |
Top PATH Facts & Tips
- PATH holds apply to all filing methods: e-file, paper, do-it-yourself software, and professional preparers.
- Only returns with EITC/ACTC are subject to PATH, but any return can be delayed for other reasons.
- After the PATH hold is lifted, most refunds still need several days to move through final IRS and banking steps.
- Expired or unrenewed ITINs can cause denial of credits, additional reviews, or longer delays.
- Filing early is still a smart move to help prevent identity theft and give you more time to respond to any IRS issues.
What To Do If You Have a PATH Message
- Confirm your status on Where’s My Refund?.
- Check your IRS Online Account and transcripts for codes like 150, 570, 846, and any 971 notice codes.
- Watch for IRS letters in the mail — respond quickly if more information is requested.
- Make sure your bank information is accurate and accounts are open and in good standing.
- Use RefundTalk PATH guides to compare your timeline with typical release patterns for your tax year.
PATH Hub Q&A: Most-Asked Questions
Click a question below to reveal a simple, on-page explanation. Use these answers alongside official IRS tools and your transcript for the full picture.
PATH Basics
After February 15 & ITIN Issues
• Check “Where’s My Refund?” and your IRS Online Account for updated messages or notices.
• Look for transcript codes such as 570 (hold), 971 (notice issued), or identity-related codes.
• Watch your mail for any IRS letters requesting income documents or identity verification.
• Respond quickly and completely to any request to avoid extra delays.
Additional review after PATH usually means the IRS needs more information before releasing your refund.
• A two-year ban on claiming the credit for reckless or intentional disregard of the rules
• A ten-year ban for fraud
• A requirement to file Form 8862 (Information To Claim Certain Credits After Disallowance) before claiming the credit again
Always review the qualification rules carefully or work with a qualified tax professional when claiming these credits.
Need Help Navigating a PATH Refund Delay?
Start with our full PATH Act refund guide, then use RefundTalk community discussions and transcript tools to compare timelines, share experiences, and better understand what your IRS messages and codes really mean.
