IRS ERC Disallowance Notices: What You Need to Know

The IRS has announced a significant development regarding the Employee Retention Credit (ERC). If you or your business filed an ERC claim, you may receive a disallowance notice or a request for repayment. The IRS is issuing these notices automatically or based on a preliminary calculation that may not fully account for the complexities of the program’s rules. With 840,000 to 980,000 notices expected to be sent in the coming months, here’s what you need to know.
What’s Happening?
The IRS initially projected the ERC program to pay out $77 billion; however, over $230 billion has already been distributed. Additionally, 1.4 million claims remain pending. Of these, 60–70% are expected to receive additional scrutiny or notices.
Using time during the recent moratorium, the IRS digitized its ERC claims process and is now sending automated disallowance notices, including:
- Notice 105C
- Notice 106C
- Notice 6577
Expect waves of 30,000 to 40,000 disallowance notices every 4–8 weeks, affecting both partial and full claims. These notices require swift action as response deadlines are often short—ranging from 15 days to a few weeks.
IRS Investigations and Audits
The IRS is also […]


