The Refund Warning Most Taxpayers Don’t Know

Beginning in the 2025 filing season (for returns processed in 2026), the IRS has begun enforcing a major modernization shift: refunds must be sent electronically unless a taxpayer meets a strict qualification for exemption.

This policy — aligned with Executive Order 14247 — is pushing taxpayers away from paper checks and toward:

• direct deposit
• Treasury-issued prepaid debit cards

And here’s the critical consequence:

If you do not provide direct deposit information, your refund may be held for a minimum of six weeks before a paper check is even initiated.

This is not a processing delay.
This is a compliance delay.

Why the IRS Is Doing This

The IRS argues that paper checks:

• are highly vulnerable to theft and fraud
• take longer to produce and deliver
• cost significantly more to process
• slow down refund distribution
• burden Postal infrastructure and taxpayer services

Electronic payment is:

• safer
• faster
• cheaper
• traceable
• verifiable

From the IRS perspective, paper checks are now a liability, not a service.

What Happens if You Don’t Provide Bank Information

Here’s the new chain of events for taxpayers who refuse or fail to enter direct deposit data:

1. Your return is approved
2. Your refund is calculated
3. The IRS attempts to send the refund electronically
4. No account exists → refund goes into manual hold
5. System triggers the six-week compliance waiting period
6. Only after that period will a paper check be considered and authorized

Meaning:

Even if your TC 846 “Refund Issued” posts, the actual payout may be delayed because the payout method is non-electronic.

The Six-Week Delay Explained

The IRS asserts this mandatory waiting period serves to:

• ensure identity accuracy
• prevent fraud
• confirm refund destination
• provide time for account verification
• encourage taxpayers to update payment information

In simple terms:
The IRS wants to give you time to switch to electronic payment — before printing a check.

What You Should Do to Avoid the Delay

Option 1: Add Direct Deposit Info When Filing

Use your:

• checking account number
• routing number

Double-check digits — mis-entries cause TC 841 reversals and month-long delays.

Option 2: Use a Treasury-approved prepaid card

If you don’t have a bank account, this is the government’s fallback option:

• no credit check
• FDIC-backed
• secure access
• PIN-protected

This ensures electronic delivery still occurs.

Option 3: Update Your IRS Online Account Banking Data

You can log in and add or change:

• bank routing
• account number
• payment method
• deposit destination

Faster than mailing a form — and without phone wait times.

Who Still Qualifies for Paper Checks?

Exceptions may be granted only for:

• incarcerated individuals
• guardianship and estate filings
• certain disability exceptions
• verified identity theft victims
• address-restricted taxpayers
• government-mandated cases

Everyone else is expected to move to electronic refunds.

Real-World Refund Timeline Examples

Scenario A — Direct Deposit Provided

TC 846 posted: refund sent immediately via ACH
Funds arrive: 1–3 business days later

Scenario B — No Bank Info

TC 846 posted: refund enters manual hold
Waiting period: 6 weeks
Paper check printing delay: additional 5–10 days
Mail delivery: another 3–7 days

Total potential delay: up to 9 weeks

The IRS paper check phase-out is no longer a recommendation — it is a structural refund policy change.

If you want your refund fast:
You must opt into electronic delivery, either through a bank account or a Treasury-issued prepaid card.

Choosing to ignore direct deposit will cost you:

• time
• convenience
• financial flexibility

Most importantly — it will cost you weeks of waiting.