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Form 15426 trips people up because the title says "Data Exchange" and the word makes it sound like anyone moving tax data can use it. It cannot. This is the IRS Governmental Liaison (GL) Data Exchange Request, an internal intake form completed by IRS business units and the federal or state agency on the other side of a proposed exchange, used to scope the request under IRC §6103 authority before any agreement is drafted.
If you are a lender or a taxpayer who actually needs an income transcript, the right paper is Form 4506-C, not this one. Form 15426 carries 20 numbered fields and no statutory deadline, and the single most common reason it comes back without action is a blank field someone skipped on the way through. Check every box before it leaves your hands.
Key Takeaways
- Form 15426 is the IRS Governmental Liaison (GL) Data Exchange Request – an administrative intake form (Rev. April 2025) used to scope a proposed data exchange between IRS business units and external federal or state government agency stakeholders before any formal agreement is drafted.
- Who uses it: IRS business units and external federal or state government agency stakeholders proposing an inter-agency data exchange with the IRS. Individual taxpayers, businesses, CPAs, EAs, and tax preparers do not file this form.
- IRC § 6103 governs the disclosure authority: § 6103 defines the confidentiality of returns and return information and is the disclosure authority for any data exchange agreement involving federal tax information. Field 9 captures the specific § 6103 subsection, or “N/A” if no FTI will be disclosed.
- Not the same as Form 4506-C: Form 4506-C is a taxpayer-signed transcript request used by lenders. Form 15426 is the inter-agency Governmental Liaison Data Exchange Request – a different form serving a different purpose.
- Processing is not immediate: Allow several weeks for IRS processing. Do not submit this form for time-critical disclosures without accounting for processing time.
- SOP tip: Build a review step for completeness – missing fields are the most common reason Form 15426 is returned without action. Check every field before submitting.
What Form 15426 Is and When to Use It
Form 15426, the “IRS Governmental Liaison (GL) Data Exchange Request,” is an administrative intake form used to establish a collaboration between an internal IRS business unit and an external federal or state government agency stakeholder before the commencement of any data exchange agreement. The legal framework for any exchange involving federal tax information is IRC § 6103, which establishes the general rule of confidentiality for returns and return information and serves as the disclosure authority for authorized exchanges.
Tax returns and return information are among the most strictly protected categories of federal data. IRC § 6103 states returns and return information shall be confidential except as authorized by the Code and is the disclosure authority of any data exchange agreement. Form 15426 is the scoping document that precedes the agreement: it captures the requesting business unit, the external agency stakeholder, the proposed data elements, the disclosure authority, and the safeguards before a formal MOU, Computer Matching Agreement, or Interagency Agreement is drafted.
The form is used whenever an IRS business unit or an external federal or state agency proposes a new data exchange collaboration with the IRS. Field 5 (Type of Collaboration Sought) is multi-select and covers Computer Matching Agreements, Memoranda of Understanding, Interagency or Reimbursable Agreements, taxpayer education collaborations, database access, and other collaboration types. The form scopes the proposal; the binding agreement is drafted afterward by the IRS Office of Privacy, Governmental Liaison and Disclosure (PGLD / GLDS) and the requesting stakeholders.
How Form 15426 Differs From Taxpayer Authorization Forms
Form 2848 (Power of Attorney) and Form 8821 (Tax Information Authorization) are taxpayer-signed forms that authorize a representative to act before the IRS or receive return information on behalf of a taxpayer. Form 15426 is a different category of document altogether: it is an IRS Governmental Liaison intake form completed by IRS business units and external government agency stakeholders to scope an inter-agency data exchange. Individual taxpayers do not sign Form 15426, and it is not used for taxpayer-to-representative or taxpayer-to-third-party disclosures.
When Form 15426 Is the Right Tool
Form 15426 is the right tool when an IRS business unit or a federal or state government agency is initiating a new data exchange collaboration with the IRS. The form is event-driven, not calendar-driven: it is submitted whenever a new exchange is proposed, with no statutory due date. If the request is from a taxpayer, lender, or other private party seeking IRS tax information, Form 15426 is not the correct form – those scenarios are handled by Forms 4506, 4506-C, 8821, or 2848 depending on the use case.
How to Complete Form 15426
Form 15426 contains 20 numbered fields organized into intake information (Fields 1–5), authority and disclosure review (Fields 6–11), and data, safeguards, and closeout (Fields 12–20). The form captures the requesting IRS business unit, the external agency stakeholder, the proposed collaboration type, the legal authority, and the data and safeguards required to scope the exchange. Completeness is critical – incomplete intake slows PGLD/GLDS review.
| Field | What to Provide | Practitioner Tip |
|---|---|---|
| Field 1: Date | Date the collaboration was first considered (MM/DD/YYYY) | Date of consideration, not a filing deadline; Form 15426 has no statutory due date |
| Field 2: Name of IRS Business Unit/Function | Every IRS business unit or function receiving or furnishing data under the proposed exchange | List all applicable units; multiple BUs can be named on a single form |
| Fields 3 & 4: Contact Information (required) | Name, title, and email for each IRS BU primary contact (Field 3) and each external agency stakeholder primary contact (Field 4) | Rows are repeatable; add rows for multiple contacts. Contact information is confidential per the form |
| Field 5: Type of Collaboration Sought | Multi-select: Computer Matching Agreement, Memorandum of Understanding, Interagency/Reimbursable Agreement, Taxpayer education, Database access, Other | The form says “check all that apply” – treat as multi-select, not single-select |
| Field 8: Agency Authority (required) | Specific legislative or regulatory citation that authorizes the requesting agency to exchange the data | Cannot be left blank; distinct from the § 6103 disclosure authority in Field 9 |
| Field 9: IRC § 6103 Disclosure Authority | Specific § 6103 subsection when federal tax information will be disclosed; enter “N/A” if no FTI will be disclosed | “N/A” is the required entry when no FTI is involved – do not leave blank |
| Fields 12 & 13: Data Description and Transmission | Field 12 lists specific data elements (e.g., taxpayer name, SSN, address, AGI); Field 13 identifies the secure transmission platform (Direct Connect, SDT, Kiteworks, SOR Mailbox) | Pair data sensitivity with platform selection so PGLD/GLDS can validate platform fit on first review |
Where to Submit
Form 15426 is processed by the IRS Office of Privacy, Governmental Liaison and Disclosure (PGLD), specifically the Governmental Liaison Data Services (GLDS) office. Burden-estimate comments and suggestions for reducing the burden are directed to [email protected], the PGLD/GLDS contact address printed on the form. The instructions do not designate a separate general submission address for the form itself.
Filing and Processing Requirements
Form 15426 does not have a fixed statutory filing deadline because it is not a tax return or information return – it is a request form submitted whenever the underlying collaboration is proposed, not on a calendar cycle. However, timing matters significantly in practice.
| Requirement | Detail |
|---|---|
| Processing Time | Typically several weeks; may be longer during peak IRS workload periods |
| Submission Method | Burden-estimate comments and inquiries directed to the IRS Office of Privacy, Governmental Liaison and Disclosure at [email protected], per the form’s burden-estimate notice; the instructions do not designate a separate general submission address |
| Completeness Requirement | Incomplete forms are returned without action; the clock does not run on an incomplete submission |
| Required Fields | Fields 3, 4, and 8 are required; Field 9 requires a specific § 6103 subsection when FTI is disclosed or “N/A” when no FTI is involved |
| Tracking | The form instructions do not designate a postal submission address or a routine receipt acknowledgment; the only contact channel printed on the form is [email protected] for burden-estimate comments |
What Happens After Submission
The IRS Governmental Liaison Data Services office reviews the request to confirm that all required fields are populated, that the agency authority in Field 8 and the § 6103 disclosure authority (or “N/A”) in Field 9 are appropriately cited, that ISA coordination with IRS Cybersecurity is documented on Field 6, and that any PCLIA determination on Field 16 is resolved. Once the scoping intake is complete, the binding data exchange agreement – MOU, Computer Matching Agreement, or Interagency Agreement – is drafted as a separate downstream document.
IRC Section 6103 and the Legal Framework
Understanding the legal framework behind Form 15426 helps practitioners advise clients and process requests correctly.
The General Rule of Tax Return Confidentiality
IRC § 6103(a) establishes that returns and return information are confidential and that IRS officers and employees may not disclose them except as authorized by the Code. This is one of the strongest data privacy protections in federal law, and violations carry civil and criminal penalties for IRS personnel. The form-based disclosure request process exists precisely because the IRS needs a formal authorization record before it can act on a disclosure request.
Permitted Disclosures Under Section 6103
IRC § 6103 contains numerous subsections authorizing specific categories of disclosure – to taxpayers themselves (§ 6103(e)), to other federal agencies for specific purposes (§ 6103(l)), and in connection with judicial and administrative proceedings (§ 6103(h)). Form 15426 is used to scope inter-agency data exchanges; when federal tax information will be disclosed under the exchange, the specific § 6103 subsection authorizing the disclosure is captured in Field 9 of the form.
What Form 15426 Captures
Form 15426 captures the information needed to scope an inter-agency data exchange: the participating IRS business units (Field 2) and external agency stakeholders (Field 4), the proposed collaboration type (Field 5), the legal authorities (Fields 8 and 9), the data elements requested (Field 12), the secure transmission platform (Field 13), and the safeguards including ISA (Field 6), SORN (Field 14), PCLIA (Field 16), and third-party contractor language (Field 18). Form 15426 is not a taxpayer-consent form.
Common Use Cases for Agency Data Exchange Requests
Form 15426 arises in a specific set of practical contexts that practitioners should recognize.
Federal or State Agency Data Exchange Collaborations
Federal and state agencies regularly need to coordinate with the IRS on data exchanges for tax administration, compliance with legislation, or taxpayer education outreach. Form 15426 is the intake document that scopes the proposed collaboration, identifies the participating IRS business unit and the external agency stakeholder, and captures the disclosure authority and safeguards before any formal agreement is drafted.
Computer Matching Agreements
Computer Matching Agreements (CMAs) are one of the data exchange agreement types named on Field 5 of Form 15426. The form captures the proposed CMA scope, the participating agencies, and the data elements involved so that the GLDS office can begin drafting the binding agreement and any associated System of Records Notice (SORN) references for Field 14.
Taxpayer Education and Outreach Collaborations
Field 5 also captures non-FTI collaborations such as taxpayer education partnerships with state agencies, database access arrangements, and other coordination types. When no federal tax information will be disclosed under the collaboration, Field 9 is completed with “N/A” and Field 8 still requires the requesting agency’s legislative or regulatory authority for the partnership.
Form 15426 vs. Form 4506-C and Other Disclosure Methods
Practitioners frequently encounter questions about which form to use for different disclosure scenarios. This overview clarifies the distinctions.
| Form / Method | Primary Use | Recipient |
|---|---|---|
| Form 4506-C | Transcript request for lenders and financial institutions via the Income Verification Express Service (IVES) | Lenders, banks, financial institutions using IVES |
| Form 4506 | Request for actual copy of tax return (not transcript) | Taxpayer or authorized representative |
| Form 8821 | Tax Information Authorization – allows the IRS to discuss or send information to the authorized person | Designated individual or firm (usually the taxpayer’s representative) |
| Form 2848 | Power of Attorney and Declaration of Representative – authorizes a representative to act on the taxpayer’s behalf before the IRS | Designated representative (attorney, CPA, or enrolled agent) |
| Form 15426 | IRS Governmental Liaison (GL) Data Exchange Request – inter-agency intake form scoping a proposed data exchange under IRC § 6103 authority | IRS business units and external federal or state government agency stakeholders |
Quick rule you can copy into your SOP: Forms 4506, 4506-C, 8821, and 2848 are taxpayer-facing authorization or transcript forms. Form 15426 is the IRS Governmental Liaison intake form completed by IRS business units and external federal or state agencies to scope an inter-agency data exchange – it is not interchangeable with the taxpayer-facing forms and is not used by individual taxpayers, CPAs, EAs, lenders, or tax preparers.
Taxpayer Rights and Privacy Protections
Form 15426 touches core taxpayer privacy rights, and practitioners should understand these protections when advising clients.
IRC § 6103 as Confidentiality and Disclosure Authority
IRC § 6103 defines the confidentiality of returns and return information and states that returns and return information shall be confidential except as authorized by the Code. The same section is the disclosure authority for any data exchange agreement: when an inter-agency exchange involves federal tax information, the specific § 6103 subsection that authorizes the disclosure is cited in Field 9 of Form 15426. If no FTI will be disclosed under the exchange, Field 9 is completed with “N/A”.
Privacy Act and SORN Requirements
A System of Records (SOR) is a group of records under the control of an agency from which information is retrieved by a name or assigned identifier. The Privacy Act of 1974 requires each agency to publish notice of its SOR (a SORN) in the Federal Register, and Field 14 of Form 15426 collects any applicable SORN link. When a Privacy and Civil Liberties Impact Assessment (PCLIA) is required, the determination is captured on Field 16; the PCLIA itself is an analysis of how information in an identifiable form is collected, stored, protected, shared, and managed to assure compliance with applicable taxpayer and employee privacy laws.
Third-Party Contractor Safeguards
If the external stakeholder uses third-party contractors for the data exchange project, Field 18 alerts the requester that additional safeguarding requirement language must be incorporated into the agreement. The use of contractors does not disqualify the exchange; it triggers additional safeguarding language to be drafted into the binding MOU, Computer Matching Agreement, or Interagency Agreement that follows the Form 15426 scoping intake.
Common Mistakes That Slow Things Down
Form 15426 looks like a quick intake, but the same handful of errors show up across IRS business units and external government agency stakeholders preparing data exchange requests. The pattern is consistent enough that I keep a one-page reference next to the form whenever a request crosses my desk.
Practical Checklists You Can Reuse
These checklists track to the actual numbered fields on Form 15426 (Rev. April 2025). Copy them into your business-unit or agency SOP and walk the form section by section before submission to the PGLD Governmental Liaison Data Services (GLDS) office.
Intake fields (1 through 5)
- Field 1: Date the collaboration was first considered, in MM/DD/YYYY format.
- Field 2: Name of every IRS business unit or function receiving or furnishing data – list all applicable units.
- Field 3: IRS business unit contact rows complete (name, title, email) for each primary contact; add rows as needed.
- Field 4: External government agency stakeholder contact rows complete (agency, name, title, email); add rows as needed.
- Field 5: Every applicable collaboration type checked – treat as multi-select across Computer Matching Agreement, Memorandum of Understanding, Interagency or Reimbursable Agreement, Taxpayer education, Database access, and Other.
- If "Other" is selected on Field 5, the free-text description is filled in.
Authority and disclosure review (6 through 11)
- Field 6: ISA Yes or No confirmed with IRS Cybersecurity (ISA ownership sits with Cyber, not the requesting BU).
- Field 7: Tax administration purpose Yes or No answered; checkboxes are mutually exclusive.
- Field 8: Legislative or regulatory authority cited – cannot be left blank.
- Field 9: Specific IRC §6103 subsection entered, or "N/A" if no federal tax information will be disclosed.
- Field 10: Purpose and intended outcome of the data exchange written in plain language.
- Field 11: Date Required in MM/DD/YYYY format, set against realistic ISA and PCLIA timelines.
Data, safeguards, and closeout (12 through 20)
- Field 12: Data description with specific elements requested (e.g., taxpayer name, SSN, address, AGI); avoid generic "all available data" language.
- Field 13: Secure transmission platform identified – Direct Connect, SDT, Kiteworks, SOR Mailbox, or another specified secure method.
- Field 14: Internal and external System of Records Notice (SORN) links provided where applicable, per Privacy Act of 1974 requirements.
- Field 15: Stakeholder responsibilities described briefly for each party.
- Field 16: PCLIA determination Yes or No completed; if Yes, PCLIA package queued in parallel.
- Field 17: Duration of the exchange stated explicitly – months, years, or event-bound end.
- Field 18: Third-party contractor use Yes or No answered; if Yes, additional safeguarding language flagged for the agreement.
- Fields 19 and 20: Other considerations and additional comments populated with any CUI, records, deliverable, or risk notes.
- Burden-estimate comments addressed to [email protected], the PGLD/GLDS contact printed on the form for that purpose.
Keep 15426 Season From Stalling
Form 15426 has no recurring filing cycle the way Form 941 or Form 1040 does – the IRS estimates the burden at roughly 60 minutes per response (per Form 15426 instructions and OMB control number 1545-2332). In practice a single request can sit for weeks once authority citations, ISA coordination, and PCLIA determinations get queued sequentially rather than in parallel, and the 60-minute number stops bearing any relationship to the calendar time the request actually consumes.
The fix is to treat Form 15426 less like a one-page intake and more like a coordinated submission pulling input from privacy, security, and business-unit owners at the same time. When the form lands at the Governmental Liaison Data Services office with the supporting authorities already named and the safeguards already scoped, review moves faster and rework drops.
- Pre-stage Field 8 (legislative authority) and Field 9 (IRC §6103 subsection or "N/A") with agency counsel before the form is opened, so both citations are confirmed at draft time rather than during review.
- Confirm ISA scope and ownership with IRS Cybersecurity before answering Field 6; the requesting business unit does not own the ISA, and routing it that way costs cycles.
- Treat Field 5 as multi-select and mark every applicable collaboration type – CMA, MOU, Interagency or Reimbursable Agreement, Taxpayer education, Database access, Other – so GLDS sees the full scope of the proposed exchange on first read.
- Resolve PCLIA scope on Field 16 in parallel with form drafting; if a PCLIA is required, complete the assessment of how identifiable information will be collected, stored, protected, shared, and managed to confirm compliance with applicable privacy laws before reviewers chase it down.
- Specify the secure transmission platform on Field 13 at the same time as the Field 12 data description, so platform fit (Direct Connect, SDT, Kiteworks, SOR Mailbox) is validated against data sensitivity upfront.
The discipline is workflow ownership: named owners on each field, parallel input from privacy and security, and a review pass before the form leaves the requesting unit. Accountably runs that same workflow discipline for U.S. tax and compliance delivery – documented SOPs, defined review layers, and a checklist that catches gaps before they reach the next stakeholder.
FAQs
What is Form 15426 used for?
Form 15426 is the IRS Governmental Liaison (GL) Data Exchange Request – an administrative intake form (Rev. April 2025, OMB 1545-2332) used to scope a proposed data exchange between an IRS business unit and an external federal or state government agency before any formal agreement is drafted. It is processed by the IRS Office of Privacy, Governmental Liaison and Disclosure (PGLD / GLDS), not by individual taxpayers, CPAs, or tax preparers.
How is Form 15426 different from Form 4506-C?
Form 4506-C is a taxpayer-signed transcript request used by lenders and financial institutions via the IRS Income Verification Express Service (IVES). Form 15426 is a different form entirely: the IRS Governmental Liaison (GL) Data Exchange Request, an inter-agency intake form completed by IRS business units and external federal or state government agency stakeholders. The two are not interchangeable and do not address the same use case.
Is taxpayer consent involved in Form 15426?
No. Form 15426 is not a taxpayer-consent disclosure form. It is an inter-agency intake form completed by IRS business units and external federal or state government agency stakeholders to scope a proposed data exchange. Where the exchange involves federal tax information, the IRC § 6103 disclosure authority is identified in Field 9 of the form by the requesting agency – no taxpayer signature is involved. If no federal tax information will be disclosed, Field 9 is completed with “N/A”.
How long does it take for the IRS to process a Form 15426 request?
Processing times vary depending on the IRS’s current workload and the complexity of the request. Practitioners should allow several weeks for processing and plan accordingly for any time-sensitive disclosure needs. There is no online tracking mechanism, so follow-up by phone may be required if no response is received within six to eight weeks.
What information is captured on Form 15426?
Field 12 (Data Description) identifies the type of data being requested (e.g., Federal Tax Information or statistical data) and specific data elements such as taxpayer name, SSN, address, or AGI. Generic “all available data” language should be avoided; the requesting agency must list specific data elements so the IRS Governmental Liaison Data Services office can scope the proposed exchange.