When Does the IRS’s 60-Day Review Clock Start?
Notice date or document submission date? Learn how IRS CP05 and CP05A waiting periods differ, when to follow up, and how to track your refund review.
You received an IRS notice saying your tax refund is under review. The letter mentions 60 days, so you mark your calendar and begin waiting.
But when does that 60-day period actually begin?
Does it start when you filed your return? When the IRS mailed the notice? Or when you submitted supporting documents?
The answer depends on the specific IRS notice you received.
For a CP05 notice, the IRS generally bases its follow-up instructions on the date printed on the notice.
For a CP05A notice, the IRS tells taxpayers to allow 60 days from the date they provided supporting documentation.
Understanding this distinction can help you avoid calling too early, missing a response deadline, or assuming your refund is guaranteed on a particular date.
CP05: Count 60 calendar days after the date printed on your notice when determining when the IRS says you may follow up.
CP05A: Count 60 calendar days from the date you provided the requested supporting documentation.
CP05B: The IRS provides a 60-day follow-up instruction but does not identify the same specific starting event on its public notice page. Follow the instructions in your actual letter.
Remember: These are follow-up guidelines, not guaranteed refund release dates.
Why the IRS 60-Day Review Clock Causes Confusion
Many taxpayers hear the phrase “60-day review” and assume every IRS refund hold follows the same schedule.
That assumption can be misleading.
The IRS issues different notices for different verification situations. Some notices tell taxpayers to wait. Others require documentation before the agency can continue reviewing the return.
That means the starting point for a follow-up period can change depending on the notice.
For example, a taxpayer with CP05 may have nothing to submit immediately.
Meanwhile, a taxpayer with CP05A may need to obtain payroll records, prepare a response, and send those documents to the IRS.
These are different processes. They should not be tracked using the same starting date.
CP05 vs. CP05A: Which Date Starts the 60 Days?
CP05
NOTICE DATE CONTROLS FOLLOW-UPStarting point: The date printed on the IRS notice.
IRS instruction: If you filed the return, no immediate action is required.
Follow-up: Do not call until 60 days after the notice date, and only if you have not received your refund or further communication.
CP05A
DOCUMENT SUBMISSION DATE CONTROLS FOLLOW-UPStarting point: The date you provided supporting documentation.
IRS instruction: Gather the requested records and respond by the date shown on your notice.
Follow-up: Allow 60 days after providing supporting documents before contacting the IRS about the review.
These instructions are published on the IRS’s official CP05 and CP05A information pages.
How the CP05 60-Day Period Works
A CP05 notice means the IRS needs additional time to verify information on your federal income tax return.
The review may involve wages, federal withholding, tax credits, or business income.
If you filed the return, the IRS says you generally do not need to take immediate action.
Instead, the agency instructs taxpayers not to call until 60 days after the notice date, and only if no refund or further communication has arrived.
Example: CP05 Notice Dated March 1
Suppose your CP05 notice is dated March 1, 2027.
| Event | Date |
|---|---|
| CP05 notice date | March 1, 2027 |
| 60 calendar days later | April 30, 2027 |
| Practical follow-up target | April 30, 2027, or the next IRS business day if needed |
If you have not received your refund or additional communication by that point, you can follow the contact instructions on your notice.
This example is a calendar illustration. It is not a promise that your refund will arrive on April 30.
The 60-day period is not automatically measured from the date you filed your return, the date your return was accepted electronically, or the date you received the notice in the mail.
The IRS’s published CP05 follow-up instruction specifically refers to the notice date.
How the CP05A 60-Day Period Works
A CP05A notice is different because the IRS needs supporting documentation to verify your income and federal income tax withholding.
Before the agency can complete the review, you must provide the records requested in the notice.
The IRS tells taxpayers to allow 60 days from the date they provided supporting documentation before contacting the agency.
That means the notice date and the document submission date serve different purposes.
Example: CP05A Notice Received in March
Suppose your CP05A notice is dated March 1, 2027.
You need time to contact your employer, obtain pay statements, and prepare the requested documentation.
You submit the documents on March 20, 2027.
| Event | Date |
|---|---|
| CP05A notice date | March 1, 2027 |
| Documents submitted | March 20, 2027 |
| 60 calendar days after submission | May 19, 2027 |
| Practical follow-up target | May 19, 2027, or the next IRS business day if needed |
In this example, the relevant 60-day follow-up period is measured from March 20, not March 1.
However, you must still meet the response deadline printed on the notice. The 60-day review guidance does not extend that deadline.
Response deadline: The date by which you must provide the requested documents.
Review follow-up date: Approximately 60 days after you provided those documents.
Do not confuse the deadline to respond with the recommended date to inquire about the IRS review.
Does the IRS Count Calendar Days or Business Days?
The CP05 and CP05A public guidance refers to 60 days, not 60 business days.
For personal tracking, count 60 calendar days from the applicable starting date.
Include weekends and holidays when making the calculation.
If your calculated follow-up date falls on a weekend or federal holiday, you may need to contact the IRS on the next day its telephone assistance is available.
This calculation is intended to help organize your follow-up. It is not a legal deadline calculation or a guarantee of case completion.
What Happens If You Submit CP05A Documents Late?
The IRS instructs taxpayers to respond to CP05A by the date shown on the notice.
If you miss that deadline, do not assume that adding 60 days to a late submission resolves the problem.
Review the notice and contact the IRS using its official instructions to determine how to proceed.
Keep records of when you submitted the documents and any communications you received afterward.
A late response may complicate the review. The outcome depends on the facts of your case and the IRS’s subsequent actions.
What If You Mailed Your Documents Instead of Uploading Them?
For CP05A, the IRS permits taxpayers to submit documentation through its Document Upload Tool, by fax, or by mail.
Its published guidance measures the 60-day period from when you provided supporting documentation.
However, taxpayers may not always know exactly when mailed documents were received or associated with their case.
For that reason, record several dates separately:
- The date you prepared your response.
- The date you mailed, faxed, or uploaded the documents.
- The delivery or submission confirmation date, if available.
- The date the IRS acknowledged receiving the response, if provided.
Do not assume a mailing date proves the IRS received or processed the documents that day.
If the precise date is uncertain, use your records when contacting the agency for clarification.
What If the IRS Sends Another Notice During the Review?
Additional IRS correspondence can change what you need to do next.
For example, a taxpayer may initially receive CP05, which generally requires no immediate action.
Later, the IRS may request supporting documentation through another notice.
If that happens, do not automatically continue following the instructions from the first letter.
Read the new correspondence carefully and determine whether it establishes a new response requirement, deadline, or follow-up instruction.
Track each notice separately.
What About the CP05B 60-Day Period?
CP05B generally concerns a difference between income reported on your return and information reported to the IRS by third parties.
The IRS requests supporting documentation and directs taxpayers to respond by the deadline printed on the notice.
Its public guidance also tells taxpayers to call the number on the notice if they have not received a refund or further communication within 60 days.
However, that public page does not specify the same notice-date or document-provided-date starting point described for CP05 and CP05A.
Therefore, do not assume CP05B follows either rule automatically.
Follow the exact instructions printed on your CP05B notice, and contact the IRS for clarification when necessary.
IRS 60-Day Review Tracking Worksheet
Use this worksheet to organize your IRS correspondence and follow-up dates.
You can print this section, fill it out, or copy the fields into a personal spreadsheet.
My IRS Refund Review Record
Submission method: ☐ Upload ☐ Fax ☐ Mail ☐ Not applicable
Current status: ☐ Waiting ☐ Documents submitted ☐ Additional information requested ☐ Resolved
Notes and IRS instructions:
For your privacy, avoid placing your full Social Security number or other sensitive identifiers on a worksheet that may be shared or stored insecurely.
How to Calculate Your IRS Follow-Up Date
Follow these steps to estimate when to contact the IRS.
- Identify the notice. Confirm whether you received CP05, CP05A, CP05B, or another IRS letter.
- Find the correct starting date. Use the notice date for CP05. For CP05A, use the date supporting documents were provided.
- Add 60 calendar days. Mark the resulting date as a follow-up target, not a guaranteed refund date.
- Check for new correspondence. Additional IRS instructions may change what you need to do.
- Contact the IRS when appropriate. Use the contact information on your notice and keep a record of the conversation.
Does the IRS Have to Release Your Refund After 60 Days?
No.
This is one of the most important facts to understand about IRS refund reviews.
The 60-day guidance does not guarantee that the IRS will issue your refund by that date.
Depending on the case, the IRS may:
- Complete its review and release the refund.
- Request additional supporting information.
- Send another notice explaining the next steps.
- Propose or make adjustments under applicable procedures.
- Continue reviewing information that has not yet been resolved.
Taxpayers should not interpret the 60-day period as a promise of payment.
Use the date to determine when the IRS recommends contacting the agency about an unresolved review. Do not rely on that date as a guaranteed deposit or check mailing date.
What Should You Do If 60 Days Have Passed?
If the applicable follow-up period has passed and you have not received your refund or additional correspondence, review your notice before contacting the IRS.
Have the following information available:
- Your IRS notice and tax year.
- A copy of the tax return under review.
- Any documents previously submitted.
- Submission or delivery confirmations.
- Your calculated follow-up date.
- Notes from earlier IRS conversations.
Use the telephone number or other contact instructions provided on your notice.
You can also check your refund status using the official Where’s My Refund? tool.
What If Your Refund Delay Is Causing Financial Hardship?
Some taxpayers rely on their refunds to pay rent, utilities, transportation expenses, or other essential bills.
If an unresolved tax problem is causing economic hardship, you may qualify for assistance from the Taxpayer Advocate Service.
TAS is an independent organization within the IRS that helps eligible taxpayers resolve problems and protect their rights.
Call 877-777-4778 or visit TaxpayerAdvocate.irs.gov.
TAS assistance is free for qualifying taxpayers. However, contacting TAS does not guarantee an immediate refund release.
Frequently Asked Questions About the IRS 60-Day Review
Does the IRS 60-day review start when I file my return?
Not under the specific CP05 and CP05A follow-up instructions. CP05 refers to the notice date. CP05A refers to the date supporting documentation was provided.
Does CP05 start from the date I receive the letter?
No. The IRS’s published CP05 guidance specifically refers to 60 days after the notice date, not the date the letter arrived in your mailbox.
Does CP05A start when the notice was issued?
The IRS’s CP05A follow-up guidance refers to the date you provided supporting documentation, rather than the notice date.
Are weekends included in the 60 days?
For a practical follow-up calculation, use calendar days. The IRS’s published CP05 and CP05A guidance does not describe the period as 60 business days.
Will my refund arrive exactly 60 days later?
No. The 60-day period is a follow-up guideline, not a guaranteed refund payment date.
Can the IRS send another letter during the review?
Yes. If you receive additional correspondence, read it carefully and follow any new instructions or deadlines.
Should I call the IRS before the 60 days are over?
For ordinary CP05 and CP05A review follow-ups, the IRS asks taxpayers to wait for the specified period. However, a separate urgent issue, suspected identity theft, or an immediate response deadline should be handled according to the applicable instructions rather than ignored.
What if I do not know when my documents were received?
Keep your mailing, fax, or upload records. If you cannot determine when your response was provided, contact the IRS when appropriate to clarify the status of your submission.
Final Thoughts: Track the Correct Date, Not Just 60 Days
The IRS’s 60-day review guidance can be confusing because different notices use different starting points.
For CP05, the notice date matters.
For CP05A, the date you provided supporting documentation matters.
For CP05B, follow the specific instructions printed on your notice rather than assuming another notice’s timing rules apply.
Keep your correspondence organized, record the important dates, and preserve copies of everything you submit.
Most importantly, remember that the 60-day period tells you when to follow up. It does not guarantee that your refund will be issued by that date.
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Official IRS Sources and Further Reading
Editorial Disclaimer: This article provides general educational information and is not individualized tax or legal advice. IRS procedures and instructions may change. Always follow your actual notice and consult a qualified tax professional when appropriate.