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IRS set to open annual CAP program for big companies

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The Internal Revenue Service is preparing to open the 2026 Compliance Assurance Process program application period for public companies with at least $10 million in assets.

The annual CAP program is scheduled to run this year from Sept. 3 to Oct. 31, 2025, and it comes at a time when the Trump administration and Republicans in Congress recently passed the One Big Beautiful Bill Act, which extends and expands tax breaks for large corporations.

If they’re accepted into the program, the IRS said it will inform applicants in February 2026.

CAP originated 20 years ago, back in 2005, and boasts real-time issue resolution through cooperative interaction between large corporate taxpayers and the IRS to improve federal tax compliance by resolving potential issues before a tax return is filed.

To be eligible to apply for CAP, applicants need to meet the following requirements:

  • Have assets of $10 million or more;
  • Be a U.S. publicly traded corporation with a legal requirement to prepare and submit SEC Forms 10-K (annual report), 10-Q (quarterly report) and 8-K (current report) or a privately held C-corporation, including foreign-owned. Privately held applicants will be required to submit audited financial statements prepared in accordance with U.S. Generally Accepted Accounting Principles (GAAP), International Financial Reporting Standards (IFRS) or another permissible method, as deemed appropriate by the IRS, specific to the taxpayer applying to the CAP program on an annual basis and unaudited financial quarterly statements. The audited financial statements must contain an unqualified audit opinion from an independent auditor. Additionally, the net income or loss per the audited financial statements must reconcile to the Schedule M-3 Line 4(a), worldwide consolidated net income (loss);
  • Not be under investigation by, or in litigation with, any government agency that would limit IRS access to current tax records.

For the 2026 CAP cycle, the IRS is continuing the open year eligibility criteria of allowing only one open filed return and one open unfiled return on the first day of the CAP applicant’s tax year. There are several exceptions to this requirement, however, such as pending Advance Pricing Agreement resolution or Competent Authority Assistance, two other programs for large corporate taxpayers.

The IRS also pointed to several other highlights and updates on the CAP program for 2026, including updates on audited financial statement requirements. General program information and the 2026 application details are available on the CAP webpage.   

The Inflation Reduction Act and the Creating Helpful Incentives to Produce Semiconductors (CHIPS) Act added several new provisions to the Tax Code for large corporate taxpayers, including the Corporate Alternative Minimum Tax, the excise tax on stock buybacks, and several clean energy credits, which will require a review for impacted taxpayers. Sine these reviews may initially extend beyond the CAP timelines, the IRS has added an exception to the closed/open year eligibility requirement, such that a tax year that remains open only because of an outstanding IRA and/or CHIPS Act tax issue will not be counted as an open filed return on the first day of the applicant’s CAP year for purposes of the CAP Eligibility return criterion.

For a new applicant currently under examination to be eligible for participation in the program, the applicant can have no more than three tax years open for examination on the first day of the CAP applicant’s tax year. The IRS examination team would determine if it is feasible these open years could close from the examination group no later than 12 months after the first day of the CAP applicant’s tax year for continued eligibility (and the accepted applicant would then concur by signing the CAP MOU).

For the 2026 CAP cycle, the IRS is continuing to use the expanded criteria announced last year. In addition to considering publicly held C corporations, the IRS said it would accept applications from privately held C corporations, including foreign owned. Privately held applicants will be required to submit audited financial statements prepared in accordance with U.S. GAAP, International Financial Reporting Standards or another permissible method, as deemed appropriate by the IRS. The audited financial statements need to be specific to the taxpayer applying to the CAP program. As such, related entity and/or parent audited financial statements will not be allowed. The audited financial statements have to contain an unqualified audit opinion from an independent auditor. In addition, the net income or loss per the audited financial statements must reconcile to the Schedule M-3 Line 4(a), worldwide consolidated net income (loss).

Also for large corporate taxpayers, the IRS announced last month that it’s proposing to streamline the examination process to reduce the time spent on cases.

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Accounting

Global ESG Reporting Standards and Double Materiality Compliance

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Corporate accounting departments face expanding reporting expectations as international sustainability disclosure standards achieve regulatory enforcement across major global jurisdictions. Chief Accounting Officers (CAOs) and corporate controllers are establishing rigorous internal accounting controls to treat Environmental, Social, and Governance (ESG) metrics with the same data precision, auditability, and governance as traditional financial statements.

Regulatory Harmonization Under Global Sustainability Frameworks
The implementation of standardized sustainability reporting frameworks—notably rules established by international sustainability accounting boards—has created unified expectations for public and large private enterprises. Corporations must report standardized metrics covering greenhouse gas emissions (Scope 1, 2, and material Scope 3), energy utilization, workforce demographics, and supply chain governance.

In Europe and other participating international jurisdictions, double materiality principles are mandatory. Under double materiality, organizations must report both how external sustainability risks impact corporate financial performance, and how internal corporate operations affect surrounding environmental and social structures.

Integrating Sustainability Metrics into Core ERP Systems
To provide auditable non-financial data, enterprise organizations are integrating specialized carbon accounting and ESG management platforms directly into core ERP systems. Automated data collectors capture energy utility invoices, logistics fuel consumption metrics, and vendor compliance records in real time.

Establishing automated, traceable data pipelines ensures that non-financial reporting is supported by clear audit trails. This structured approach allows external financial auditors to provide reasonable assurance on sustainability disclosures during annual corporate reporting cycles.

Financial Impacts and Capital Market Disclosure
Accurate ESG reporting directly influences corporate cost of capital and institutional credit ratings. Commercial lenders and institutional asset managers systematically incorporate sustainability metrics into risk pricing models. Companies that demonstrate transparent, verifiable progress in operational energy efficiency and climate risk mitigation benefit from expanded access to green bond markets and lower debt pricing.

Action Steps for Accounting Leadership
1. Implement Double Materiality Frameworks: Conduct comprehensive assessments to identify material financial and operational sustainability metrics.
2. Build Auditable Non-Financial Data Pipelines: Automate ESG data collection within core accounting software to ensure data integrity.
3. Align Sustainability with Annual Financial Filings: Prepare non-financial disclosures concurrently with financial statements to satisfy regulatory audit expectations.

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Accounting

Modernizing Internal Controls: Machine Learning and Continuous Monitoring in Auditing

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Internal audit departments and corporate risk managers are modernizing internal control frameworks by shifting from periodic sampling techniques to continuous monitoring and machine learning analytics. As operational data volumes increase across enterprise organizations, automated control testing ensures financial integrity, prevents corporate fraud, and streamlines annual audit engagements.

The Limitation of Periodic Audit Sampling
Historically, internal and external auditors evaluated internal controls by reviewing random samples of financial transactions—often analyzing less than five percent of total ledger entries. In complex enterprise environments, periodic sampling methods carry inherent risks of overlooking localized financial misstatements, unauthorized disbursements, or operational control breakdowns.

In 2026, progressive internal audit functions are utilizing automated continuous monitoring platforms that evaluate one hundred percent of financial transactions in real time. Continuous control auditing systems continuously monitor general ledger entries, procurement approvals, and expense reimbursements across all operating subsidiaries.

AI-Powered Fraud Detection and Anomaly Identification
Machine learning models trained on historical corporate financial data excel at identifying subtle transactional anomalies that indicate potential fraud or operational error. Automated systems instantly flag duplicate invoice payments, unapproved vendor creation, unusual journal entry timing, and unauthorized override of authority thresholds.

When an anomaly is detected, the automated auditing platform generates an instant risk alert, allowing internal audit teams to investigate root causes immediately. Early detection prevents minor operational errors from escalating into material weaknesses in financial reporting.

Streamlining External Audit Preparation
Continuous internal control monitoring delivers significant benefits during annual external financial audits. External audit firms can review continuous audit logs and automated control testing documentation, reducing the time required for manual field testing.

This integrated approach lowers overall audit compliance fees, reduces administrative burdens on corporate accounting staff, and provides senior management and audit committees with real-time visibility into the organization’s overall risk profile.

Core Implementation Guidelines
1. Transition to 100% Data Testing: Replace legacy sampling methods with automated continuous audit monitoring systems.
2. Deploy Anomaly Detection Algorithms: Implement machine learning models to identify unauthorized transactions and operational control overrides.
3. Align Internal and External Audit Workflows: Coordinate continuous control testing protocols with external auditors to optimize annual compliance cycles.

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Accounting

Automated Tax Compliance and Global Regulatory Harmonization in 2026

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Corporate tax accounting departments are navigating an era of unprecedented regulatory complexity as global tax harmonization frameworks take full effect alongside real-time digital tax reporting mandates. Tax directors and accounting teams are adopting cloud-based tax compliance automation tools to manage multi-jurisdictional tax liabilities and satisfy stringent reporting rules across international jurisdictions.

Implementation of Global Minimum Tax Provisions
The implementation of international tax reform agreements—notably the Pillar Two global minimum tax framework—has reshaped multinational corporate tax planning. Multinational enterprises with consolidated revenues exceeding established thresholds must ensure an effective tax rate of at least 15% across every jurisdiction in which they operate.

Accounting teams are implementing specialized tax calculation modules integrated directly into enterprise resource planning (ERP) platforms. These automated tools calculate effective tax rates per country, identify top-up tax liabilities, and generate standardized compliance documentation required by national tax authorities.

Real-Time Digital Invoicing and E-Reporting Mandates
Tax authorities across Europe, Latin America, and Asia-Pacific have enacted mandatory electronic invoicing (e-invoicing) and continuous transaction controls (CTC). Under these systems, corporate transaction data must be submitted electronically to government portals in real time at the point of sale or invoice issuance.

This shift toward continuous digital tax reporting eliminates traditional annual tax audits in favor of ongoing automated compliance monitoring. Accounting departments are upgrading invoicing software to ensure seamless XML data formatting, digital signature authentication, and real-time validation against tax authority databases.

Automation and Data Analytics in Corporate Tax Strategy
To keep pace with dynamic tax legislation, tax departments are transitioning from reactive compliance teams to proactive strategic advisors. Machine learning algorithms analyze corporate transactional data to identify tax credits, research and development (R&D) incentives, and cross-border transfer pricing adjustments.

By automating routine tax return filings and calculations, corporate tax directors can focus on long-term capital structuring, evaluating the tax implications of corporate mergers, and optimizing international supply chain networks.

Strategic Priorities for Tax Executives
1. ERP System Upgrades: Ensure enterprise software is capable of generating real-time, granular tax data required for global minimum tax compliance.
2. E-Invoicing Integration: Implement scalable e-invoicing platforms to satisfy regional continuous transaction control regulations.
3. Strategic Tax Analytics: Utilize predictive tax modeling tools to evaluate structural changes in corporate operations and cross-border trade.

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