PATH Act imposes an ITIN expiration schedule, threatening millions of tax filers

Congress enacted the Protecting Americans from Tax Hikes (PATH) Act on December 18, 2015, embedding a rolling expiration schedule into the ITIN program for the first time. ITINs issued before 2013 were assigned expiration dates based on their middle digits, and any ITIN unused for three consecutive tax years would automatically expire — requiring holders to file Form W-7 with original identity documents to renew. Advocacy groups warned that the renewal burden fell disproportionately on elderly, rural, and low-literacy immigrant filers, and that expired ITINs could trigger refund delays, loss of child tax credits, and account closures at banks requiring active tax identification numbers.