IRS Enforcement Trends: What FY 2021 to 2025 Data Show

What the five-year data show

• Individual examination closures fell from 659,012 in FY 2021 to 441,578 in FY 2025.
• Closed examinations of returns reporting $5 million to $10 million of total positive income rose from 1,299 to 3,741.
• Automated Underreporter cases closed fell, while the average assessment per closed case rose from about $4,300 to about $6,000.

Completed audits shifted toward higher-income returns

Closed examinations of earned income tax credit returns fell from 277,936 in FY 2021 to 93,857 in FY 2025. Over that same period, closures rose in the higher total-positive-income bands. In FY 2025, field examinations accounted for about 90% of closed examinations in each band above $5 million, compared with about 11% across individual examinations generally. That describes the completed-work mix, not an audit-rate forecast.

Most enforcement contact is not an audit

In FY 2025, the Automated Underreporter program closed 987,460 cases, and the Automated Substitute for Return program closed 592,773 cases. A CP2000 notice follows information-return matching and is procedurally different from an examination. A substitute return may omit deductions, credits, basis, elections, and facts the taxpayer has not substantiated, which is why an unfiled-return case often requires a return and supporting records rather than a bare response to the assessment.

The FY 2025 Data Book also reports 161,908 ASFR actual closures, compared with 1,169 in FY 2024. The reporting change is striking, but a completed-case count does not identify when a current notice was selected or what a particular taxpayer should expect.

How to use the data

The Data Book is most useful for understanding the kind of contact involved. A notice, an examination request, a proposed adjustment, and an unfiled-return assessment follow different procedures and deadlines. Readers dealing with a notice can review the firm's IRS audit letter guide. A matter involving several years, business records, a proposed deficiency, or an unresolved nonfiler issue may call for a more specific review through Tax Controversy & Litigation.

Methodology and sources

Examination figures are from IRS Data Book Table 3-2. Automated-program figures are from Table 3-8. The fiscal-year tables measure cases closed and related assessments, not audit coverage or current selection probability. The FY 2025 edition covers October 1, 2024 through September 30, 2025. See the IRS Data Book and the IRS information-reporting table.

A TIGTA workforce report issued after FY 2025 reported agency-wide staffing changes and revenue-agent separations. It does not establish how many examinations the IRS is opening now. Read the TIGTA report.