Dealers are strongly encouraged to sign-up to receive updates from IRS e-News subscriptions. Select "e-news for business" and sign-up for e-news for clean vehicle industry. Q1. Can I come back into IRS Energy Credits Online tool and complete my registration for the advance payment program at another time? (updated Sept. 10, 2024) A. Yes. A dealer who is registered to submit time of sale (TOS), or seller, reports will have the ability to continue their registration to be able to participate in the advance payment program at any time. They can do so by clicking on their "Time of Sale Report Registration" within their account. Q2. Is dealer registration separate for previously-owned and new vehicle sales? (added Nov. 1, 2023) A. No. Registered dealers may submit time of sale reports for both new and previously-owned vehicle sales. Please note, only dealers licensed by a state, the District of Columbia, an Indian tribal government, or any Alaska Native Corporation may submit time of sale reports for previously-owned vehicles. Q3. How will the dealer be informed of a registration status update? (updated Sept. 10, 2024) A. Upon successful registration for time of sale reporting, you will see a green ‘Success’ banner and an option to register for advance payment. On the Dealers and Sellers landing page, you will also see links to complete time of sale reports. Upon successful registration for advance payment, you will see a green ‘Success’ banner, and you will find a dealer registration ID assigned on your dealer registration form. You can confirm a successful advance payment registration when you submit a time of sale and the option under step three, Transfer Election, is available. If you are not registered for advance payment, you will not be able to select the radio button, “Yes, transfer credit to dealer/seller.” See Publication 5867 PDF for additional details. Q4. What information is required for dealer registration? (updated Sept. 10, 2024) A. Dealers should be prepared to create a Clean Energy Business Account using general business information (e.g., business EIN, business mailing address, phone number, email, etc.) and authorize an individual representative of the dealer to access dealer registration. The entity name needs to match the name shown on the most recent IRS notice or IRS records. Dealers registering for advance payment will have to provide additional information on their state license and bank account. Uploading a copy of your state license, a current bank letter (dated within six months), a current bank statement, and a voided check to your advance payment registration may expedite any review process. Once your advance payment registration is approved by the IRS, you would need to re-submit your registration to make changes to your bank account information. Please see Q8 below. Q5. Does a dealer need to be licensed by a state or other jurisdiction to register? (updated Sept. 10, 2024) A. To submit time of sale reports for IRC section 25E and/or register to receive advance payments, a dealer must be licensed by a state, District of Columbia, Indian tribal government, or Alaska Native Corporation. Non-licensed dealers (sellers) may register to submit time of sale reports for IRC section 30D only. Non-licensed dealers (sellers) are not eligible to register to accept credit transfers from electing buyers through the advance payment program. Q6. Why is my dealer registration pending review? (added Nov. 1, 2023) A. A dealer registration may be pending review because of a failed systematic validation of information provided to the IRS. Q7. If my registration fails initially, will I have another opportunity to register? (added Nov. 1, 2023) A. Yes. A dealer may attempt registration again. Q8. How do I edit information within my dealer registration? (updated Sept. 10, 2024) A. Contact information (such as phone number or email address) may be edited at any time on the dealer registration page. To edit any other information, such as bank account number or dealer state license number, a user must re-register with new information. See Publication 5867 PDF beginning on page 30 for additional instruction. Please note that it may take 15 days or longer for any re-registration to process. During this waiting period, you will be unable to complete time of sale reporting and unable to initiate credit transfers. Q9. If I run into difficulty at any point in the registration process, who should I contact? (updated Oct. 22, 2024) A. Please contact the IRS through secure messaging using your IRS Energy Credits Online account. Q10. What address do I enter on the dealer registration form? (updated Sept. 10, 2024) A. The dealer’s business mailing address must match IRS records. Check the dealer's online account or a recent notice from the IRS to confirm the name and business mailing address on file with the IRS. The address must be in a U.S. state or the District of Columbia. Use approved abbreviations, such as "St" for street and "Ave" for avenue. If the dealer's business mailing address has changed, an authorized representative should notify the IRS. Q11. What defines the term of "business"? (added Nov. 1, 2023) A. An organization or entity legally entitled to conduct trade or commerce in any given industry that creates an IRS Energy Credits Online account. Q12. Many dealers have multiple locations. Does each location need to register? How do I know which of my entities should register? (updated Sept. 10, 2024) A. To register as a dealer, your business must have an EIN. If you have multiple dealers filed on a partnership or S corporation return, you should complete registration for the EIN that files a federal income tax return. You will only be able to upload one license with the registration. You may upload any of the licenses associated with the partnership or S Corporation. If you have multiple dealers which file a return on a consolidated return, then each subsidiary dealer should complete registration using each subsidiary dealer EIN. On a consolidated return, each subsidiary is recognized as an individual federal income tax return combining into the one consolidated return. One individual can complete dealer registration for multiple entities if they are authorized to do so for each entity. Q13. Should dealers submit time of sale reports for 2023 sales through IRS Energy Credits Online? (updated Sept. 10, 2024) A. No. Revenue Procedure 2022-42, Section 6.03 provides that dealers must file reports within fifteen days after the end of the calendar year (i.e., January 15, 2024). The IRS extended the due date to February 15, 2024. As a result, for vehicles placed in service in calendar year 2023, you must have submitted the required information about a qualifying clean vehicle sale to the IRS by February 15, 2024. For additional information, please see Clean vehicle credit seller or dealer requirements. Q14. Why am I getting a submission error when I attempt to create my clean energy business account? (updated Oct. 22, 2024) A. Please send us a message through secure messaging in your IRS Energy Credits Online account if you encounter an error when creating your account. Please attach to the email a screenshot of any message that populates on the screen. Q15. Our account is under "manual review", saying that our bank account information could not be validated. Should we be concerned at this time? (updated Sept. 10, 2024) A. There is no reason to be concerned. This only means that the information could not be validated automatically. The IRS will reach out if additional information is required to validate the bank account information. Uploading a copy of your state license, a current bank letter (dated within six months), a current bank statement, and a voided check to your advance payment registration may expedite any review process. Q16. We have two dealers that use the same Employer Identification Number (EIN) but have two different dealer ID numbers from the same state, and the system will not allow registration of both dealers because they have the same EIN. How should we proceed? (updated Sept. 10, 2024) A. Please see Q12 above. Q17. Will the IRS be providing the standard disclosure forms and attestations from the buyer that dealers are required to provide buyers? (updated Sept. 10, 2024) A. No. See Frequently asked questions about the New, Previously Owned and Qualified Commercial Clean Vehicles Credit: Topic H Q5 for information a registered dealer needs to provide to the buyer and when. This is in addition to the attestation that is done through the portal, by checking the box and e-Signature. Q18. What is the definition of a periodic report? Is that the same as a vehicle history report (i.e., CarFax)? (updated Sept. 10, 2024) A. Periodic reports are reports submitted by qualified manufacturers reporting VINs of vehicles the qualified manufacturer believes are eligible for the clean vehicle credit. The periodic reports will also include battery capacity and attestations, and other elements based on the Code under which the qualified manufacturer believes the credit applies. The IRS reviews and either accepts or rejects the VINs submitted by the qualified manufacturers. Approved VINs are added to clean energy database through a manual process completed by the IRS for VIN matching at the time of sale. Similarly, when a time of sale report is submitted by a registered dealer, the clean energy database is updated to reflect that the eligible VIN has been placed in service and a credit claimed. Periodic reports are different from vehicle history reports. Vehicle history report means a report that provides the ownership history of a motor vehicle that is issued by a data provider approved by the National Motor Vehicle Title Information System. Q19. Is the dealer required to give their EIN only to the IRS or to the buyer as well? (updated Sept. 10, 2024) A. The dealer will provide the buyer with the validated time of sale report which is to be used by the buyer at the time of filing of their income tax return. The time of sale report to be provided to the buyer is a PDF download generated in the Energy Credits Online account. The buyer will use the time of sale report to file Form 8936, Schedule A PDF, when filing their federal income tax return. The time of sale report will contain your dealer name, EIN and address. This is the only dealer identifying information that the buyer will require. Q20. Where can we find the website to register? (updated Jan. 16, 2024) A. You can register at IRS Energy Credits Online. The IRS uses ID.me, a technology provider, to provide identity verification and sign-in services. If you have an ID.me account, sign in using your existing account. If you do not have an account you can create an account through the dealer registration link on IRS Energy Credits Online. Q21. What do you do if a sale falls through after you have already submitted for the credit? Will there be a process to correct a reported sale and/or report a rescinded sale? (updated Nov. 25, 2024) A. In the event the dealer wishes to update or rescind certain information on a time of sale report for a scrivener's error or cancellation of sale, the time of sale report can be voided within 48 hours of submission via a checkbox on IRS Energy Credits Online. After 48 hours, the advance payment of the credit, if elected, will be paid to the registered dealer and the registered dealer is unable to void the time of sale report. Additional instructions on updates to scrivener’s errors outside of the 48-hour void period are forthcoming. For returns and cancellations after the 48-hour void period, refer to Publication 5867-B, Clean Vehicle Return and Cancellation User Guide PDF. The registered dealer will be required to repay in full any advance payments received. For additional information on determining the 48-hour window, please see Q40 below. The dealer must notify the buyer within 3 calendar days of updating or rescinding the time of sale report and provide the buyer a copy. The dealer must also notify the buyer within 3 calendar days of the IRS's rejection of the updated or rescinded report. See Rev. Proc. 2023-33, section 7.03(4), Updating and Rescinding of Seller Reports. For questions on subsequent eligibility of a returned or cancelled VIN, please see Frequently asked questions about the New, Previously Owned and Qualified Commercial Clean Vehicles Credit: Topic A Q12 (new) or Topic D Q12 (previously owned). Q22. Will customers leasing a vehicle be able to claim a clean vehicle credit? (updated Nov. 25, 2024) A. Leased vehicles can qualify for the new clean vehicle credit under IRC 30D or for the commercial clean vehicle credit under IRC 45W. The credit must be claimed by the leasing company (lessor) on their Federal Income Tax return. Leasing companies are businesses and there is no option to transfer the credit to the dealer. The lessee is not the owner and is not eligible to claim the credit. Additional information can be found in Frequently asked questions about Qualified Commercial Clean Vehicle Credit: Topic G. If you have submitted a time of sale report for a leased vehicle, you will need to CANCEL your time of sale report. For more information see Frequently asked questions for clean vehicle returns and cancellations: Q6. Q23. Who should register the dealer? How are additional employees added? (updated Sept. 10, 2024) A. One authorized individual should register the dealer with an account as the primary user, or “super user”. After registration, the primary user can approve access of additional authorized employees. The primary user will indicate what roles each individual can be assigned, secondary user or additional primary user. There is no limit to the number of accounts that can be associated with a dealer. Additional authorized employees can be approved by the primary user beginning in December 2023. As a best practice, it is recommended that each account have at least two primary users and that any additional primary users are added as soon as possible. Each user should create an ID.me account through the dealer registration link on IRS Energy Credits Online. Once the request is submitted by a new user, the new user should notify the "super user" or "Clean Energy Officer" to approve the request by visiting the "manage business users" tab of the entity's account. See Publication 5902, Clean Energy Authorization Permission Management User Guide for more information. Q24.Can a dealer with multiple locations register under one account? (updated Sept. 10, 2024) A. This depends on how the locations are treated for tax purposes. Please see Q12 above. Q25. Can one person register multiple dealers? (updated Sept. 10, 2024) A. One person can register multiple dealers so long as they are authorized to do so. An individual representative of the dealer who is currently authorized to legally bind the dealer in these matters can complete the initial registration through IRS Energy Credits Online. To register as a dealer, your business must have an EIN. If you have multiple EINs for your business, please see Q12 above. Q26. If there are multiple dealers that are classified as non-filing disregarded single member LLC entities underneath a consolidated tax return, can each one register to receive credits or does the filing entity have to register on behalf of all dealers? (updated Sept. 10, 2024) A. Please see Q12 and Q25 above. Q27. We have multiple franchises under one EIN, will we have to input all locations under that EIN? (updated Sept. 10, 2024) A. If there is one EIN for multiple dealers, they can be added under one registration. In the event that there are two EINs, there will be two registrations. Please see Q12 above for additional information. Q28. My registration received a "Business Activity Code Error - Pending Review". What does this mean? (updated Sept. 10, 2024) A. In order to register, the dealer must have a valid EIN and an NAICS code. The NAICS code, or Business Activity Code, must be within certain parameters. If the NAICS code on file is outside of these parameters, the registration will undergo manual review. The IRS will reach out if additional information is required to clarify or confirm the NAICS code on file. Q29. Are there any concerns with having the personal ID.me account linked to the business' clean energy account, such as if the employee were to leave the company? (updated Sept. 10, 2024) A. The IRS uses ID.me, a technology provider, for identity verification and sign-in services. ID.me will validate the identity of the individual who is logging in and not the dealer. ID.me does not communicate the individual's account information, such as username, password, or filing information, back to the dealer. Similarly, no user will have access to the dealer’s federal income tax filing information, employment tax filing information, etc. through the clean energy business account. When the initial Dealer Registration is completed, this should be done by a primary user. Additional primary or secondary users can be approved by the primary user beginning in December 2023. Any primary user can both assign and disable additional accounts associated with the dealer as necessary. Q30. Will additional users need ID.me account? (updated Jan. 16, 2024) A. Yes. The IRS uses ID.me, a technology provider, for identity verification and sign-in services. Each additional user should create an account through the dealer registration link on IRS Energy Credits Online. Q31. How does this work with dealers that file their federal income tax return as part of a consolidated group? (updated Sept. 10, 2024) A. Please see Q12 above. Q32. What is the deadline for submitting time of sale reports after the sale of a vehicle? (updated Sept. 10, 2024) For vehicle sales occurring in calendar year 2023, please see Q13 above. For vehicle sales occurring in calendar year 2024 and later, dealers must file reports within 3 days of the time of sale, through IRS Energy Credits Online. For further details see Rev. Proc. 2022-42 and Rev. Proc. 2023-33. The buyer is responsible for filing Form 8936 PDF, or other required forms, to claim the tax credit with their annual federal income tax return filing, regardless of whether the election to transfer the credit to the dealer was made. Q33. Can the entity registering on IRS ECO be a disregarded entity for Federal tax purposes. We would like to be able to register disregarded single member LLCs as they are the dealer and operationally this is more efficient. Further, the regarded corporate holding company is not a dealer. (updated Sept. 10, 2024) A. To register as a dealer, your business must have an EIN with a federal income tax filing requirement. Because there is no federal income tax filing requirement associated with a disregarded single member LLC, the dealer registration should be submitted under the corporate holding company. However, an individual, or individuals, representing the disregarded single member LLC can create separate accounts to submit time of sale reports under the corporate holding company. Each user should create an account through the dealer registration link on IRS Energy Credits Online. Q34. I operate a sole proprietorship. How can I register as a dealer? (updated Sept. 10, 2024) A. First, if not already done, you will need to apply for and be assigned an Employer Identification Number (EIN). Please allow ten to fourteen days after your new EIN is assigned to attempt dealer registration. Then, you may proceed to create a Clean Energy account through your Business Online Account (BOLA). Login to or create a personal ID.me account. Click on “start authorization” below “Clean Energy and Manufacturing Credits”. Follow prompts to create your account. Please refer to Publication 5867, Clean Vehicle Dealer and Seller Energy Credits Online Registration User Guide PDF for step-by-step instructions, beginning on page five. Note: The registered name must be the sole proprietor’s name, not the DBA name line. The name must match IRS records and the sole proprietor’s name should be in the format last name first followed by first name. Q35. As a dealer, am I required to participate in the Clean Vehicle Program? (updated April 26, 2024) A. No, participation in the Clean Vehicle Program is voluntary. However, beginning in 2024, only sales reported through the Energy Credits Online (ECO) tool are qualified sales for purposes of claiming the Clean Vehicle Credit. A buyer cannot claim the credit on a clean vehicle that has not been reported through ECO. Additionally, in order for the buyer to elect to transfer the clean vehicle credit to the dealer, the dealer must be successfully registered through the ECO portal for the advance payment program. Q36. I indicated that the buyer was not electing to transfer the credit at the time I submitted the time of sale report. Can I revise a time of sale report to change the buyer election to transfer the credit to the dealer? (updated Nov. 25, 2024) A. No. The election to transfer the credit must be made by the buyer prior to or on the day of sale. The transfer election is final. See also Frequently asked questions about the New, Previously-Owned and Qualified Commercial Clean Vehicles Credit: Topic H, Question 13. If you believe extenuating circumstances exist regarding whether the buyer timely elected to transfer the credit, please login to IRS ECO and send the IRS a secure message. See Frequently asked questions for clean vehicle returns and cancellations: Q16. Q37. If I was not approved to receive advance payments at the time I submitted a Clean Vehicle time of sale report, can I revise that time of sale report later to indicate the buyer elected to transfer the credit? (updated Sept. 10, 2024) A. No. Buyers can only elect to transfer the clean vehicle credit prior to or on the day of sale to the selling dealer that is, at the time of election, successfully registered through the ECO portal for the advance payment program. Successful registration in the advance payment program is not retroactive. The transfer election is final. See also Frequently asked questions about the New, Previously-Owned and Qualified Commercial Clean Vehicles Credit: Topic H, Question 13. Q38. I indicated that the buyer did not elect to transfer the credit at the time I submitted the time of sale report. Can the buyer still claim the clean vehicle credit? (updated Sept. 10, 2024) A. An eligible buyer who receives a successfully submitted time of sale report and who did not elect to transfer the credit at the time of sale, may elect to claim the clean vehicle credit on their federal tax return using Form 8936, along with Form 8936, Schedule A PDF. Q39. Is the Time of Sale Report a legal document? (added April 5, 2024) A. The Time of Sale Report is a legal document. The dealer attests, via check-the-box method, that the report is true and correct. This attestation is made under penalties of perjury. Q40. I input a time of sale report at 9 a.m. Eastern Standard Time (EST). Why does the submission time reflect 2 p.m.? (updated May 20, 2024) A. The Energy Credits Online (ECO) portal operates on Greenwich Mean Time (GMT), five hours ahead of Eastern Standard Time, or four hours ahead of Eastern Daylight Time, dependent upon the time of year. The only time reflected in ECO is GMT. You must convert GMT to your local time. Please take caution when determining your 48-hour void period, ensuring that you are converting the time submitted from GMT to your time zone in order to determine the correct 48-hour void period ending time. Q41. My time-of-sale report is under review. What can I do? Can I void the report while it is under review? (updated Sept. 10, 2024) A. The only action you can take is to submit supporting documentation when requested. An IRS representative will contact you if additional information is required. Check your Submitted Time-of-Sale Reports page periodically for status updates on the report. You will not be able to void the report while it is under review.
