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IRS subcontractors left sensitive paper documents exposed before destroying them

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The Internal Revenue Service’s program for destroying sensitive paper documents needs to be improved after an inspector general’s report found its contractor was leaving many of the documents easily accessible from open containers and storage bins.

The Treasury Inspector General for Tax Administration released a report Thursday faulting the IRS’s sensitive document destruction program. TIGTA found during some of its site visits to IRS facilities that sensitive documents had been stored in open containers. During other site visits, TIGTA discovered bin disposal slots that had been altered or left in poor condition, allowing ready access to discarded sensitive documents. TIGTA evaluators found bins in which they were able to reach their hands through the bin disposal slot and easily retrieve discarded sensitive documents.

Document disposal bin at the IRS with papers being pulled out
An example from the TIGTA report of a bin slot opening being too large

TIGTA

The inspection came after TIGTA’s Office of Inspections and Evaluations received a referral from its Office of Audit regarding concerns about the IRS’s sensitive document destruction program. The evaluation found that improved management oversight is necessary to ensure sensitive documents are properly safeguarded prior to destruction. 

The problems seem to be related to a change in contract terms. The IRS changed its billing criteria in its national contract for sensitive document destruction in fiscal year 2022. The national contract, which covers 387 IRS facilities across the country, went from weight-based billing to billing based on the number and type of bins. 

“When the IRS pays for actual sensitive document destruction services rendered, it is being good stewards of its operating budget,” said the report. “In addition, the proper collection and destruction of sensitive documents ensures the protection of tax information until it is destroyed. However, when billing concerns arise or when sensitive documents get exposed to unauthorized disclosure or access prior to destruction, the IRS could be paying for services not received or disclosure law fines. In addition, the IRS could face an erosion of the public trust, which could adversely affect voluntary compliance, the foundation of our nation’s tax system.”

The report comes at a critical time for the IRS, when it faces the prospect of a $20.2 billion cut in its enforcement funding from the Inflation Reduction Act because the continuing resolution that Congress passed last week to avoid a government shutdown repeated language from an earlier continuing resolution that had mandated a previous $20.2 billion cut. 

TIGTA noted that the IRS receives and creates a significant volume of sensitive documents and is responsible for protecting sensitive documents from receipt to disposal. It found the IRS has not established or communicated to personnel at its various facilities the standard operating procedures for sensitive document destruction to ensure uniformity and consistency. IRS officials did not know what specific sensitive document destruction procedures were used at 110 of its facilities. 

The IRS no longer performs on-site inspections at facilities where sensitive documents are brought for destruction to ensure proper disposal, the report noted. Instead it seems to leave the job to its contractor and subcontractors. The IRS contracts the job to a national vendor that relies on local subcontractors to complete the destruction of sensitive documents. 

But the IRS didn’t put in place appropriate processes and procedures to ensure billing with its main contractor was accurate. TIGTA’s review of invoices paid for October 2023 found charges for more bins than reported by the vendor as being retrieved for destruction. The IRS didn’t determine the optimal number, type or size of bins needed at its facilities. 

TIGTA made 12 recommendations in the report, suggesting the chief of facilities management and security services at the IRS should develop standard operating procedures for sensitive document safeguarding and destruction; immediately evaluate the 110 facilities to ensure sensitive document safeguards and destruction procedures are in place; replace bins that have been damaged and altered; perform annual inspections of all facilities used by subcontractors for sensitive document destruction; complete a cost-benefit analysis to ensure optimal bin size and number of bins at all facilities; and develop processes and procedures to ensure that the IRS is only paying for full bins serviced. IRS officials agreed with seven of TIGTA’s 12 recommendations and agreed in principle to the other five recommendations. 

The IRS’s most recent contract includes provisions requiring site inspections by a National Association for Information Destruction certified inspector, the IRS noted in response to the report. The IRS contract now requires for the first time that all vendors be NAID certified. 

“IRS staff who discard [sensitive but unclassified] materials with regular trash and recycling are violating long-established policies on which they were trained during orientation and about which they receive refresher training annually,” wrote Julia Caldwell, acting chief of facilities management and security services at the IRS, in response to the report.

The IRS agreed to establish a communication plan to provide more frequent periodic reminders to employees as well as put up posters on sensitive document destruction at all IRS locations. 

Caldwell noted that due to a change in industry standards from billing by weight to billing by bin, bin fill rate data are not required for contract performance, and contended that requiring the contractor to document bin fill rates for all bins serviced would not add value to the sensitive document destruction process. Her department does not have enough personnel to staff every IRS location, she pointed out, especially the smaller, remote locations, and it would be too costly to travel to those locations to verify service on the document bins.

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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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