Topic I — Frequently asked questions about registering a dealer/seller for seller reporting and Clean Vehicle Tax Credit transfers

Updated FAQs were released to the public in Fact Sheet 2024-26 PDF, July 2024.

The Inflation Reduction Act of 2022 (IRA) makes several changes to the tax credit provided in section 30D of the Internal Revenue Code (Code) for qualified plug-in electric drive motor vehicles, including adding fuel cell vehicles to the section 30D tax credit. The IRA also added a new credit for previously owned clean vehicles under section 25E of the Code.

These FAQs provide detail on how the IRA revises the credit available under section 30D (New Clean Vehicle Credit) for individuals and businesses, and information on the credit available under section 25E (Previously Owned Clean Vehicle Credit) for individuals, and the new credit for qualified commercial clean vehicles under section 45W of the Code.

Q1. May a buyer claim the New or Previously Owned Clean Vehicle Tax Credit if the dealer or seller of the vehicle is not registered with the IRS? (added Oct. 6, 2023)

A1. No. Starting for vehicles placed in service Jan. 1, 2024 or later, buyers will only be able to claim credits if the seller has registered with the IRS and successfully submits a seller report through IRS Energy Credits Online. This submission is done at the time of sale through IRS Energy Credits Online, and the seller must provide a copy of the successfully submitted seller report to the buyer.

Q2. Who must submit seller reports through IRS Energy Credits Online and who is eligible to participate in the advance payment program? (added Oct. 6, 2023)

A2. All dealers and sellers must submit seller reports through IRS Energy Credits Online for vehicles placed in service beginning Jan. 1, 2024. Registered dealers that provide required information through IRS Energy Credits Online and are in tax compliance may become eligible to receive payments from the advance payment program once their registration information is verified by the IRS.

Q3. Who should complete the initial registration on behalf of the dealer or seller? (added Oct. 6, 2023)

A3. An individual representative of the dealer or seller who is currently authorized to legally bind the dealer or seller in these matters can complete the initial registration through IRS Energy Credits Online. Starting December 2023, dealers and sellers will be able to authorize more than one employee to make representations on their behalf through IRS Energy Credits Online.

Q4. What information is required for dealer registration? (updated July 26, 2024)

A4. Dealers should be prepared to create a Clean Energy Business Account using general business information (including business EIN, address, phone number and email) and authorize an individual representative of the dealer to access dealer registration. The entity name must match the name shown on the most recent IRS Notice or IRS records. Dealers registering for advance payments will have to provide additional information such as their state license and bank account, detailed on IRS Energy Credits Online.

Please note: You are unable to create a Clean Energy Business Account without a business EIN. If you are a sole-proprietorship operating under an SSN or ITIN, you will need to establish a business EIN. Also, for all registered dealers, once your advance payment registration is approved by the IRS, you will not be able to change your bank account information without re-completing the advance payment registration process and being re-approved by the IRS.

Q5. Does a dealer need to be state licensed to register? (added Oct. 6, 2023)

A5. In order to submit seller reports for previously owned clean vehicles or register to receive advance payments, a dealer must be licensed by a state, the District of Columbia, an Indian tribal government or any Alaska Native Corporation to engage in the sale of vehicles. Non-licensed dealers (sellers) must still be registered through IRS Energy Credits Online to submit seller reports.

Q6. What is the difference between registering for seller reporting and the advance payment program? (added Oct. 6, 2023)

A6. A registration to submit seller reports will allow dealers and sellers the ability to submit seller reports through IRS Energy Credits Online when selling eligible vehicles. This does not include the ability to receive advance payments. A registration for the advance payment program grants the dealer the ability to submit seller reports when selling a vehicle and submit a request for an advance payment to the IRS. Only licensed dealers may register to receive advance payments.

Q7. Is a dealer required to register for both seller reporting and the advance payment program? (added Oct. 6, 2023)

A6. No. A dealer or seller can be registered to submit seller reports without registering to receive advance payments. However, only licensed dealers can be registered to receive advance payments.

Q8. Once a dealer is registered, when can they start to receiving advance payments? (added Oct. 6, 2023)

A8. Buyers may transfer their credit to the dealer, thereby allowing dealers to initiate an advance payment request, beginning Jan. 1, 2024.

Q9. Can a dealer come back into IRS Clean Energy Online and complete its advance payment registration at another time? (added Oct. 6, 2023)

A9. Yes. A dealer who is registered to submit seller reports will have the ability to continue their registration to receive advance payments at any time.

Q10. Is dealer registration separate for used and new vehicle sales? (added Oct. 6, 2023)

A10. No. Registered dealers may submit seller reports for both new and previously owned clean vehicle sales. Please note, only licensed dealers may submit seller reports for previously owned clean vehicles.

Q11. How will the dealer be informed of a registration status update? (added Oct. 6, 2023)

A11. Registration status updates will be displayed in IRS Energy Credits Online.

Q12. If registration fails initially, will the dealer have another opportunity to register? (added Oct. 6, 2023)

A12. Yes. A dealer may attempt registration again.

Q13. Why did my dealership receive a tax compliance error? (updated July 26, 2024)

A13. A tax compliance error is a result of an overdue tax return, form, and/or unpaid federal tax debt. A dealer will not be able to complete registration for the advance payment program until compliance issues are addressed.

Q14. What does my dealership need to do to be in tax compliance? What if my dealership is not in tax compliance? How can my dealership become compliant to participate in the advance payment program? (updated July 26, 2024)

A14. Dealer tax compliance means that all required federal information and tax returns of the dealer have been filed, including for federal income and employment tax purposes, and all federal tax, penalties and interest due of the dealer as of the time of completing dealer advance payment registration. For federal tax, penalties, and interest amounts owed, a dealer that has entered into an installment agreement with the IRS for which a dealer is current on its obligations is treated as being in dealer tax compliance for those amounts.

If the dealer is not in dealer tax compliance for any of the taxable periods during the last five taxable years, then the dealer may complete its initial registration with the IRS, but the dealer will not be eligible for the advance payment program until the compliance issue is resolved. The IRS will notify the dealer that the dealer is not in dealer tax compliance, and the dealer will have the opportunity to address any failure through regular procedures. If the failure is corrected, the IRS will complete the dealer's registration for the advance payment program, and, provided all other requirements are met, the dealer will then be allowed to participate in the advance payment program.

Q15. Do qualified manufacturers who are direct sellers need to register? (added Oct. 6, 2023)

A15. Qualified manufacturers who are direct sellers of vehicles must complete dealer registration in order to submit seller reports and receive an advance payment when a credit is transferred.

Q16. How do I edit information within my dealer registration? (added Oct. 6, 2023)

A16. Contact information, such as phone number or email address, may be edited at any time by clicking into the dealer registration page. To edit any other information, a user must re-register with new information.

Q17. Does my dealer registration expire? (added Oct. 6, 2023)

A17. A dealer registration expires after 10 years.

Q18. If my dealership runs into difficulty at any point in the registration process, who should I contact? (added Oct. 6, 2023)

A18. Please contact irs.clean.vehicles.dealer.info@irs.gov with questions.

Q19. My dealer registration is pending review due to a business activity mismatch because my business also operates in another category and that is my primary business. How do I rectify this? (added July 26, 2024)

A19. Your registration will undergo a manual review. If we need additional information, we will reach out to you.

Q20. How long does it take for my dealer registration to be accepted after we submit on the IRS Energy Credit Online portal? Who can I contact to expedite the registration process? (added July 26, 2024)

A20. Generally, this can take up to 15 days after submitting the dealer registration and bank validation. There is no way to expedite this process. To transfer credits and receive advance payments, the minimum waiting period is 15 days. It is important that you are timely in responding to requests to obtain documentation to verify the bank information in order to reduce the time your advance payment registration is pending.

Q21. How do we add additional users for clean energy accounts on IRS Energy Credits Online? (added July 26, 2024)

A21. Please refer to Publication 5902, Permission Management and Additional Authorization User Guide PDF, beginning on page 28, for detailed instructions on adding additional users.

Follow the steps below to request and receive access:

• Each additional user will need an ID.me account. If they do not have one, they must create one.
• The user should then register to request access to their entity’s IRS Energy online account at IRS.gov/cvregister.
• Once you submit the request notify the “super user” or “Clean Energy Officer” to approve your request by visiting the “manage business users” tab of the entity’s account.

Q22. I never received my dealer registration ID. How do I obtain this? (added July 26, 2024)

A22. Please log in and click on “Dealer Registration Form” for your Dealer Registration ID.

Q23. Other than the “Success” banner at registration, does the dealer get a confirmation email? If the dealer doesn’t catch the “success” banner and log out, will they see the banner when they log back in or will it be gone? (added July 26, 2024)

A23. A confirmation email will not be sent, and the success banner will be gone after the user logs out. For registration status, please log in and go to your Dealer Registration Form.

Q24. I am receiving a “Service is Currently Unavailable” error when I attempt to register my entity. The name I am registering begins with “The”. What can I do? (added July 26, 2024)

A24. Entities registering with “The” in front of their name should register without the word “The,” unless it is followed by one word. The system may not validate the entity name beginning with “The.” Using the word “The” before the entity name could create a “Service is Currently Unavailable” message. Example, The ABC Company, should register as ABC Company. Please see Using the correct name control in e-filing corporate tax returns for additional information.

Q25. An employee of the dealership left the company and was the person who set up the account. Should the dealership set up a new account? How can the dealership delete the employee who left the company? (added July 26, 2024)

A25. Choose with care any employee who will serve as the primary user on the Clean Energy Business Account. When you create a Clean Energy Business account and receive the following message: “You completed the account creation process. You’ll have access to your Clean Energy business account once a Clean Energy Officer approves your request.”, it means a primary user from the company created a Clean Energy Business Account. If the primary user was the only person with access to the account, please reach out to the individual who created the account to have them login and approve your account as an additional Clean Energy Officer. The new Clean Energy Officer can then remove the first user’s access. See Publication 5902, Permission Management and Additional Authorization User Guide PDF for instructions on adding and removing users.

Please contact irs.clean.vehicles.dealer.info@irs.gov with questions.

Q26. Are dealers required to report anything if they had no qualifying sales? (added July 26, 2024)

A26. Only qualifying sales for sales of new or previously owned clean vehicles should be reported.

Q27. If the dealer does not have the buyer’s Social Security number (SSN), should the dealer leave that field blank or not list that sale? What if a buyer refuses to provide their SSN? (added July 26, 2024)

A27. The federal statute requires the buyer to provide their tax identification number (TIN) in order to be eligible for the credit. Additionally, dealers are required to report qualifying sales for a buyer to be eligible to claim the credit. If the dealer does not have the buyer’s TIN information, the dealer will have to obtain it from the buyer. If this information isn’t provided, the buyer may not elect to transfer the credit and will be ineligible to claim a tax credit for that vehicle on their tax return.

Q28. Will the buyer qualify for the credit with an individual taxpayer identification number (ITIN)? (added July 26, 2024)

A28. Yes, individuals with active ITINs are eligible buyers. Additional information can be found at ITIN expiration FAQs.

Q29. When a dealer inputs the vehicle’s VIN, what does the portal check that might impact eligibility? (added July 26, 2024)

A29. IRS Energy Credits Online provides real-time confirmation of a vehicle’s eligibility using VINs provided by manufacturers. If the VIN doesn’t qualify, the dealer will receive an error message that the vehicle is not eligible for the credit and that the dealer needs to contact the manufacturer for additional information.

Q30. We have multiple dealers registered in IRS Energy Credit Online. One dealer has been unable to successfully register. Can we use one of our successfully registered dealers to submit seller reports? (added July 26, 2024)

A30. Yes. If a dealer that has not yet successfully registered transfers the vehicle prior to the time of sale to one of the registered dealers so that the registered dealer completes the sale to the buyer, the registered dealer may submit the seller report.