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The first time one of my team pulled up Form 15398-A, they assumed from the number that it was another taxpayer return and started looking for line items and a due date. There are none. Form 15398-A is an internal IRS intake that asks a form’s owner to describe how that form lives inside the IRS – who fills it, where it goes, what system stores the data, and how long it is kept. Once you see it as a metadata questionnaire about another form rather than a tax filing, every field on it makes sense.
Key Takeaways
- Form 15398-A is the internal IRS Form Requirements intake (Rev. 10-2024, Cat. No. 94646I). It records metadata about another IRS form: ownership, processing path, data destinations, retention, and DMAF readiness. It is not a tax return or information return.
- Who completes it: IRS form owners and process owners, not taxpayers or third parties. The fields ask about the form being documented, not about the person filling out 15398-A.
- It carries a revision date, not a tax year. Cite it as Rev. 10-2024 or Revised October 2024. It contains no dollar amounts, thresholds, line items, or inflation-adjusted figures, and OBBBA 2025 values do not apply.
- It has no public filing deadline. It is submitted on demand during form-lifecycle events: new-form approval, revision review, retirement, or conversion to a Digital Mobile Adaptive Form (DMAF).
- Main pitfall: entering the form number as printed. Item 1 must be normalized – drop the word form, spaces, and punctuation, so 706 GS(D-1) becomes 706GSD1.
- SOP tip: file one Form 15398-A per target form. To retire a form, complete item 6 (why it is no longer used and what replaced it) and file a separate Product Submission Request (PSR).
What Form 15398-A Is and Who Uses It
Form 15398-A, titled “IRS Form Requirements,” is an internal IRS administrative intake form. Its assistive-text header reads “Form 15398-A. Revised October 2024. Catalog Number 94646I. IRS Form Requirements. Department of the Treasury. Internal Revenue Service.” The form is used to capture metadata about another IRS form: who owns it, how it is received and processed, where its data ends up, how long it is retained, and whether it is ready to become a Digital Mobile Adaptive Form.
It is not a tax return, schedule, or information return, and taxpayers do not file it. The user-type question on the form – “Is this form completed and submitted by external users or internal IRS employees” – refers to the form being documented, not to Form 15398-A itself. That single distinction is the source of most confusion about this form.
Because Form 15398-A describes other forms, it carries a revision date (Rev. 10-2024) rather than a tax year. It contains no monetary thresholds, dollar amounts, penalties, or filing fees. There is nothing on it to update when inflation-adjusted figures change, so values such as the 2025 standard deduction or SALT cap have no bearing here.
Who Completes the Form
The filer is the IRS form owner or process owner for the form being documented. The form defines the process owner as the person “responsible for defining how the form is received and processed and how the information is used and stored.” That is a different role from the form owner, who is the content steward. On a single Form 15398-A you may name both, plus a separate point of contact for any computer system that stores the form’s data.
One Form Per Documented Form
Item 1 (Form number) is a single-value field, so you file one Form 15398-A per target IRS form rather than one record covering a whole form family. For variants such as the 1040 series, file a separate Form 15398-A for each one instead of listing several in a single record.
How to Complete Form 15398-A
The form opens with identifying items for the documented form, then branches based on who uses that form. Many fields are select-all-that-apply, and every required field is marked with an asterisk (*). The table below covers the core fields that appear before the external/internal branch.
| Item / Field | What to Provide | Practitioner Tip |
|---|---|---|
| Item 1 – Form number* | The number and suffix of the form being documented | Drop the word form, spaces, and punctuation. The form’s own example: 706 GS(D-1) is entered as 706GSD1 |
| Item 2 – Catalog number* | The Cat. No. of the documented form | It is printed at the bottom of the form being documented; external readers can also use the IRS public Forms & Instructions page |
| Form title* | The official title of the form being documented | Match the title as printed on the form, not a shorthand |
| Is this form active and in use?* | Yes or No | Answering No routes you to item 6 and the retirement instructions |
| Completed by external users or internal IRS employees?* | External user or Internal IRS employee | Internal applies only if the form never reaches the taxpayer; if the IRS fills part and then sends it to the taxpayer, it is External |
| Type of use* | The most appropriate type of use | Select what reflects current use even if it differs from the official catalog listing |
Select-All-That-Apply and Other (Explain)
Several questions accept multiple answers: who initiates the form, who completes it, submission channels, where it is received, the processing medium, the data destination, the data-entry method, and what happens to it after processing. Each of these carries an “Other (explain)” option, and selecting Other triggers a paired free-text field that becomes required. Leaving that explanation blank produces an incomplete record, so fill it in the same step.
External vs. Internal User Branches
After the user-type question, Form 15398-A splits into two field sets. The branches share only the identifying items (form number, catalog number, title, owner). Reading the branch-specific labels carefully is the difference between a clean record and a confused one. This is one of the more common questions we field about the form.
| Topic | External user branch | Internal IRS employee branch |
|---|---|---|
| How it moves | Submission channels (select all that apply) | How is this form sent, submitted, or delivered |
| Where it lands | Where is the form received | Where does the form go |
| Signature question | Will the form be accepted without a signature (Yes/No) | How many signatures are required (None / One / Two or more) |
What Counts as an Internal Form
An “Internal IRS employee” form is one that is only completed by the IRS and never sent to the taxpayer at all. The form’s own note is clear: if the IRS completes part of the form and then sends it to the taxpayer, it is classified as an “External user” form. Classification depends on whether the form ever reaches the taxpayer, not on who initiated it. A correspondence insert the IRS starts but the taxpayer fills out is External.
Send Channels on the Internal Branch
The internal branch replaces submission channels with its own list of send channels: Mail (submitted or delivered on paper), Email, Fax, Automated upload/routing, and Manual upload. The “Where does the form go” question then offers: another IRS employee/team; uploaded or routed to an internal IRS system or database; or to an individual or system outside of the IRS.
Submission, Processing, and Data Destinations
A large part of Form 15398-A maps how a form’s data moves end to end. These are select-all-that-apply questions, so a single form can carry several answers in each category.
Submission Channels and Receipt Locations
On the external branch, submission channels include Mail, Email, Fax, Online – fillable PDF, Online – adaptive form, In-Person, Taxpayer Digital Communication (TDC), and Document Upload Tool (DUT). The receipt-location question (“Where is the form received”) offers Mailroom, Office, Campus, Email, Shared folder, and Individual. Campus refers to an IRS service campus such as Ogden, Kansas City, or Austin; Individual means a specific employee inbox.
Processing Medium and Data Entry
“In what medium is the form processed” accepts Paper, PDF, or Extracted data (case management system). If the form’s information ends up in a computer system or database, the filer also answers the data-entry method: Manual transcription, Scanning, OCR, or Automatically (no human touch). Selecting Yes to the database question makes both the destination and data-entry fields required.
Form Data Destination Systems
The destination question lists the IRS systems where a form’s data may be stored, including ACDS, AMS, CDE, CDW, DCS, ECM, IDRS, IMS, IMF, BMF, the Return Preparer Database, and TAMIS. There is also a “None, form info only on paper” option for forms that never enter a computer system. Whenever a database is used, the filer must name a point of contact or subject-matter expert for that system, who may differ from the form owner.
Signatures, Retention, and Point of Contact
Form 15398-A also records how a form is signed and how long it is kept. The signature question differs by branch, but both branches ask why a signature is needed.
Signature Requirements
On the external branch the filer answers “Will the form be accepted without a signature” (Yes/No). On the internal branch the filer answers “How many signatures are required” with No signatures, One signature, or Two or more signatures. Both branches require a free-text answer to what determines the need for a signature – for example, a statement of intent or a perjury statement. On the internal branch, when signatures are required, the filer must list all parties required to sign.
Retention
“How many years is the form retained” is a required field. The form gives no “N/A” guidance for retention, so a value must be entered even when the practical answer is indefinitely or none. Quick rule you can copy into your SOP: confirm the records-control schedule for the documented form before answering, so the retention figure matches the governing schedule rather than a guess.
Point of Contact and Multiple BODs
When a database stores the form’s data, name a point of contact or subject-matter expert for that system. If multiple Business Operating Divisions (BODs) are involved in receiving, processing, or using the data, answering Yes triggers two follow-ups: the additional BOD organizational symbols and the process owners from each BOD. The BOD field expects a colon-separated organizational symbol such as SBSE:ETA:RA, not a written-out division name.
DMAF Readiness and Pre-Screening
A recurring purpose of Form 15398-A is to gather what the IRS needs to build a Digital Mobile Adaptive Form (DMAF) version of the documented form. DMAF is an IRS form-modernization program that converts static PDFs into device-adaptive online forms with structured submissions. It is the receiving architecture, not a tax-filing product for taxpayers.
The Three Domain Fields
The form asks for the 3 Domain fields that IRS users will use to search and sort DMAF submissions. The cardinality is fixed: provide exactly three, not more and not fewer. These are the attributes the IRS will index so a form’s structured submissions can be retrieved and grouped. If the form owner thinks fewer would do, they still choose the three most useful for search and sort.
Pre-Screening Questions
The form also asks whether there are pre-screening questions to add to the DMAF version. Answering Yes triggers a required description. The wording differs by branch: the external branch asks about the pre-screening questions and user journey, while the internal branch asks about pre-screening questions and routing fields. Reading the branch-specific label matters here, because the two are not interchangeable.
Why the PDF Looks Blank in Some Readers
The official Form 15398-A PDF is a dynamic XFA form built in Adobe LiveCycle Designer 6.5 and requires Adobe Reader 8 or higher. In a standard PDF viewer it shows only an “Adobe Reader required” placeholder rather than the form body, which leads some users to assume it is empty. The content lives in the embedded XFA template. Many CPA firms and in-house teams hit this the first time they open it.
Retiring a Form: Item 6 and the PSR
Form 15398-A is also used when a form is being taken out of service. The retirement path opens from the active-status question and has a specific two-step rule that is easy to get wrong.
The Retirement Branch
If “Is this form active and in use” is answered No, the filer reaches item 6, “Why is it no longer used.” This is a required field, and it asks for two things: why the form is not needed and what, if anything, replaced it. Explaining only the why, without naming the replacement, leaves the record incomplete.
Item 6 Does Not Retire the Form by Itself
The form text is explicit that item 6 only describes the retirement. To actually remove the form from the active form listing, a separate Product Submission Request (PSR) must be submitted. Form 15398-A documents the change; the PSR effects it. Small errors create big cleanup – file both, not just one.
Optional Reference Fields
Not every field carries the required asterisk. If an Internal Revenue Manual (IRM) or SERP procedure describes the receipt and processing of the form, the filer is asked to list it, but this is conditional rather than mandatory. Submission volume is also optional precision: a rough estimate of the most recent annual count is acceptable, and “N/A” is allowed when the volume is not known.
Why It Is Not a Tax Return
The single most common error with Form 15398-A is treating it as something taxpayers file. The breakdown below contrasts what it captures with what a tax form captures.
| Attribute | A typical tax form | Form 15398-A |
|---|---|---|
| Who files it | Taxpayer or authorized representative | IRS form owner or process owner |
| What it captures | Tax data – income, deductions, liability | Metadata about another IRS form’s lifecycle |
| Period reference | A tax year | A revision date (Rev. 10-2024) |
| Deadline | A statutory due date | None – submitted on demand during form-lifecycle events |
Form 15398-A has no monetary thresholds, no line items, and no filing fee. It exists so the IRS can document, modernize, and retire its own catalog of forms in a consistent way. If you find yourself looking for a refund, a credit, or a payment voucher on it, you are reading the wrong kind of form – this one describes other forms, it does not collect tax.
Common Mistakes That Slow Things Down
These are the errors we see most often when teams document a form on 15398-A. None involve dollar amounts, because the form has none – they are all about classification and completeness.
Practical Checklists You Can Reuse
Copy these into your SOP. The first covers the shared identifying items; the second covers the branch-specific and lifecycle fields.
Core intake checklist
0 / 7- Item 1: enter the documented form’s number normalized (no “form,” no spaces, no punctuation).
- Item 2: enter the catalog number from the bottom of the documented form.
- Enter the form title exactly as printed.
- Answer “Is this form active and in use” (Yes routes to active fields; No routes to item 6).
- Set user type: External user or Internal IRS employee (taxpayer-visibility test).
- Pick the type of use that reflects current use, even if it differs from the catalog listing.
- Name the form owner and process owner; confirm whether multiple BODs are involved.
Data-flow and lifecycle checklist
0 / 7- Select submission channels (external) or send channels (internal); fill any “Other” explanation.
- Record where the form is received or where it goes, per branch.
- Capture processing medium and, if a database is used, the data-entry method and destination systems.
- Name a point of contact or SME for any storage system.
- Answer the signature question for your branch and explain what triggers the need for a signature.
- Enter retention years (a value is required) and post-processing disposition.
- Provide DMAF readiness: exactly three Domain fields and any pre-screening questions.
Keep Form 15398-A Records From Stalling
If your team supports an IRS-facing workflow or an in-house tax function that touches IRS form-modernization work, Form 15398-A records tend to stall for the same reasons: nobody is sure who the process owner is, the data-destination systems are named inconsistently across forms, and the DMAF Domain fields get debated rather than decided. Those are documentation problems, not tax problems.
From my side of the desk, the fix is structure. Keep one record per form, normalize the form number the same way every time, hold a short list of the IRS destination-system acronyms (IDRS, IMF, BMF, AMS, and so on) so they are entered consistently, and decide the three Domain fields up front rather than at submission. Small errors create big cleanup. Clean, consistent metadata is what lets the next person pick up a form’s record without re-deriving how it moves through the IRS.
FAQs
Who completes Form 15398-A?
Form 15398-A, titled IRS Form Requirements (Rev. 10-2024), is completed by the IRS form owners and process owners responsible for an IRS form during its lifecycle. It is an internal administrative intake that records metadata about another IRS form, such as ownership, processing path, data destinations, retention, and DMAF readiness. It is not a tax return and is not filed by taxpayers.
Is Form 15398-A a tax return that taxpayers file?
No. Form 15398-A collects form-lifecycle metadata about other IRS forms, not tax data. It has no monetary thresholds, no line items, and no filing deadline. Treating it as a tax return, withholding form, or information return is the most common misconception, because the user-type question (External user vs Internal IRS employee) refers to the form being documented, not to Form 15398-A itself.
How do you enter the form number in item 1?
Item 1 asks for the form number of the IRS form being documented. The instruction is to enter only the number and suffix, omit the word form, and drop spaces and punctuation. The form gives the example that 706 GS(D-1) should be entered as 706GSD1. Item 2 then asks for the catalog number (Cat. No.), found at the bottom of the form being documented.
Does Form 15398-A have a filing deadline?
No. Form 15398-A has no statutory or published due date. It is submitted on demand by IRS form owners as part of form-lifecycle events such as new-form approval, revision review, retirement, or conversion to a Digital Mobile Adaptive Form (DMAF). The form carries a revision date (Rev. 10-2024), not a tax year, and contains no inflation-adjusted values.
What happens if the documented form is no longer used?
If “Is this form active and in use” is answered No, the filer reaches item 6, which requires an explanation of why the form is no longer used and what, if anything, replaced it. Form 15398-A only describes the retirement. A separate Product Submission Request (PSR) must still be filed to actually retire the form from the active form listing.