The IRS has made new functionality for processing returns and cancellations operational in the Energy Credits Online (ECO) portal, as well as a new secure two-way messaging tool for communicating with the IRS. The IRS will also soon announce a temporary suspension of the submission deadline for 2024 time-of-sale reports.
After extensive engagement with NADA, the IRS took these actions to provide long-awaited relief for dealers who encountered problems when using the ECO portal, including the issues outlined in NADA’s May 30th letter regarding outstanding reimbursements for clean vehicle tax credits applied to 2024 clean vehicle sales.
The new functionality will enable dealers to process returns and cancellations after the 48-hour void period for submitted time-of-sale reports, which is especially important for dealers that issued time-of-sale reports for lease transactions in error. Dealers that need to repay an advance payment for a cancelled time-of-sale report will receive an invoice from pay.gov via the e-mail provided when they registered for the Advance Payment program. For returns and cancellations regarding vehicles that were not placed in service, dealers should expect the VINs to be available for a new credit transfer transaction approximately 2-3 weeks after submitting the return or cancellation in the portal.
Importantly, dealers that submitted regular time-of-sale reports mistakenly after applying credit transfers at the time of sale must request assistance from the IRS through the new messaging tool to correct these submissions.
The affected dealers must work directly with the IRS to demonstrate that their customers made knowing and voluntary credit transfers, and that all legal requirements of the advance payment program were satisfied. This confirmation would ordinarily be established via the attestations displayed in the portal for credit transfers, but because the transactions were not entered correctly, the affected dealers must provide explanations and documentation to the IRS for review via the new messaging tool to obtain relief.
Once implemented, the suspension of the 3-day time-of-sale report deadline will enable dealers who missed the deadline, either because their registration remained pending or for other reasons, to submit time-of-sale reports and seek reimbursement for credits applied to their outstanding 2024 transactions.
The IRS will be hosting office hours sessions during which IRS representatives will be available to answer questions and help familiarize dealers with using the new functionality and messaging tool. Registration for each session is limited to 500 participants.
To provide guidance for dealers, the IRS issued an ECO Secure Messaging User Guide, and a Clean Vehicle Return User Guide. These materials will also be available soon on NADA’s Clean Vehicle Incentives webpage. Please note you will need your NADA login credentials to access the page.