Form 3115 Due Date: How to Determine When to File
Understand the nuanced filing requirements for Form 3115. The deadline to change your accounting method depends on the nature of the change itself.
Form 3115, Application for Change in Accounting Method, is filed with the Internal Revenue Service (IRS) to change how a taxpayer accounts for an item for tax purposes. This can range from an overarching change, like switching from the cash to the accrual method, to an isolated adjustment. The filing deadline for Form 3115 is not a single date; it depends on the type of accounting method change being requested.
Automatic vs Non-Automatic Consent Changes
The IRS separates accounting method changes into two categories: automatic and non-automatic, which determines the filing process and deadline. An automatic consent change is one for which the IRS has granted advance permission by publishing a list of pre-approved changes. Because the IRS has already outlined the terms, taxpayers do not need to secure individual approval before making the change.
A common example of an automatic change is correcting an asset’s depreciation method. Another frequent change involves inventory adjustments. These pre-approved changes are identified on Form 3115 by a Designated Change Number (DCN). If a DCN exists for the change, it falls under automatic consent procedures.
A non-automatic consent change is any modification not on the automatic change list. These changes require filing Form 3115 to request permission from the IRS National Office before implementation. A user fee is required with a non-automatic change request.
Filing Deadline for Automatic Changes
For an automatic consent change, the original, unsigned Form 3115 must be attached to the federal income tax return for the year of the change, filed by its due date including extensions. For instance, a calendar-year business making a change for the 2025 tax year attaches Form 3115 to the 2025 tax return filed in 2026.
A signed, duplicate copy of Form 3115 must also be filed separately with the IRS service center in Ogden, Utah. This duplicate copy must be sent no earlier than the first day of the tax year of the change and no later than when the original is filed with the tax return. Both filings are required for the application to be valid.
Filing Deadline for Non-Automatic Changes
The filing deadline for a non-automatic change is different from the automatic procedure. Form 3115 must be filed with the IRS National Office during the tax year for which the change is requested, with a deadline of the last day of that tax year.
For a taxpayer using the calendar year, a request for a non-automatic change for the 2025 tax year must be filed by December 31, 2025. The taxpayer cannot implement the new accounting method until receiving a formal consent letter from the IRS. Filing early in the year is recommended to allow for IRS review time.
Requesting Late Filing Relief
If a taxpayer misses a deadline, relief may be available. For an automatic change, a six-month extension applies if the taxpayer timely filed their tax return but omitted Form 3115. To use this extension, the taxpayer must file an amended return with the form attached within six months of the original return’s due date, excluding extensions.
For other situations, including non-automatic changes, taxpayers may seek an extension known as “9100 relief.” This requires submitting a request, paying a user fee, and establishing that they acted reasonably and in good faith, and that the extension will not prejudice the government’s interests.
To request 9100 relief, the taxpayer must provide a comprehensive affidavit explaining the failure to file on time. The IRS evaluates this to determine if the actions were reasonable, such as being unaware of the requirement despite exercising due diligence or being impacted by events beyond the taxpayer’s control.