IRS Delays Implementation of Form 6765 Changes for R&D Tax Credit Filers

Key Takeaways:

The IRS announced a significant delay in enhanced reporting requirements for Form 6765 (Credit for Increasing Research Activities) via IR-2025-99. Section G business component reporting remains optional for tax year 2025 (returns filed in 2026) and becomes mandatory starting tax year 2026 for most filers (with limited exceptions). This transitional relief provides critical time to strengthen documentation, internal controls, and QRE tracking amid ongoing IRS scrutiny of R&D claims.

• Section G Remains Optional in 2025
  ‍For tax year 2025, all filers can choose whether to complete Section G, which requires detailed reporting by business component (e.g., product, process, software) and QRE categories (wages, supplies, contract research, computer rentals).
• Section G Becomes Mandatory in 2026
  ‍Starting tax year 2026, most claimants must provide this granular reporting. Exceptions apply to Qualified Small Businesses (QSBs) electing payroll tax credits under IRC §41(h) and small taxpayers in controlled groups under IRC §448(c) with QREs ≤ $1.5 million and gross receipts ≤ $50 million.
• Extended Transition for Refund Claims
  ‍Taxpayers have 45 days to perfect research credit refund claims after IRS notification, with this relief extended through January 10, 2027.
• Why the Delay Matters
  ‍The extension (effective through March 31, 2026) allows companies to build robust processes for compliance, reducing risks of claim denials or audits when requirements tighten.
• Recommended Actions Now
  ‍Begin tracking QREs at the business-component level, align cross-functional teams (tax, finance, engineering), review eligibility for exceptions, maintain rigorous project documentation, and consider submitting feedback to the IRS before March 31, 2026.

This delay offers breathing room but signals permanent higher standards ahead. Proactive preparation in 2025 will position filers for seamless compliance and sustained credit benefits. Read on for full details, FAQs, and filing guidance.

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Introduction

On October 1, 2025, the IRS announced a delay in its implementation of major changes to Form 6765 (Credit for Increasing Research Activities), extending the effective date to March 31, 2026 (IR-2025-99).

Most notably, the requirement to complete Section G (Business Component Reporting), which demands detailed reporting of research activities and related expenses, remains optional for 2025 and will become mandatory in 2026 for most filers.

This extension gives taxpayers and advisors more time to strengthen documentation processes, internal controls, and cross-team coordination, all of which will be critical for sustaining R&D credit eligibility under the IRS’s heightened transparency and reporting standards.

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Key Highlights

1. Section G Remains Optional for 2025

• Applies to tax year 2025 (returns filed in 2026).
  
• Section G requires taxpayers to report:
  
  • Type of business component (product, process, software, or other)
    
  • QREs by category (wages, supplies, contract research, computer rentals)
    
  • Brief descriptions of related research activities

➡️ By keeping Section G optional, the IRS is signaling flexibility, giving companies time to upgrade documentation and internal tracking before the requirement becomes binding.

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2. Section G Becomes Mandatory in 2026 (With Limited Exceptions)

• Starting with tax year 2026, most filers must complete Section G.
  
• Exceptions apply for smaller taxpayers:
  
  • Qualified Small Businesses (QSBs) under IRC § 41(h)(3) applying the credit against payroll taxes
    
  • Small taxpayers within controlled groups under IRC § 448(c):
    
    • QREs ≤ $1.5 million
      
    • Gross receipts ≤ $50 million

➡️ The IRS will issue final instructions in January 2026, confirming thresholds and possible additional relief.

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3. Extended Transition Period for Refund Claims

• Taxpayers still have 45 days to perfect a research credit refund claim after IRS notification.
  
• This grace period is now extended through January 10, 2027, reducing the risk of losing credits due to incomplete or late documentation.
  
  

Quick Reference Table

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What Businesses Should Do Now

1. Prepare Early – Begin tracking QREs at the business-component level in 2025.
   
2. Coordinate Across Teams – Align tax, finance, and engineering to capture complete and accurate R&D data.
   
3. Check Eligibility – Determine if your company qualifies as a QSB or meets §448(c) thresholds.
   
4. Document Rigorously – Keep detailed records for each project and related expenses.
   
5. Engage Proactively – Submit comments to the IRS before March 31, 2026 to shape final guidance.
   

💡 For deeper practical guidance, check Strike’s R&D Tax Credit Guide.

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Conclusion

The IRS’s delay buys time but not much. Companies that begin adapting now will be well-positioned to meet the 2026 mandatory reporting standards without risking compliance gaps or lost credits.

At Strike Tax Advisory, our team specializes exclusively in R&D credit compliance, documentation, and defense, helping clients navigate complex IRS updates with confidence.

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Disclaimer

This article summarizes IRS guidance as of October 2025, including the October 1 announcement (IR-2025-99). It is intended for informational purposes only and does not constitute tax advice. Consult a qualified tax professional for advice specific to your organization.