IRS Notices
IRS CP05 Notice: Refund Under Review and What to Do (2025)
The short answer: a CP05 notice means the IRS is reviewing your tax return and holding your refund while it verifies your income, withholding, and any credits. In most cases you don't need to do anything — just wait. The IRS gives itself up to 60 days from the notice date to finish and release your money.
⏱ Your timeline: the IRS has up to 60 days from the date printed on the CP05 to complete its review. There is usually no deadline for you — unless a follow-up CP05A arrives asking for documents, in which case respond by the date it lists. If 60 days pass with no update, you can call the IRS or open a case with the Taxpayer Advocate Service.
What a CP05 notice actually means
A CP05 notice is the IRS telling you: "We received your return, and we're taking a closer look before we send your refund." That's it. The IRS calls this a refund review, and it's holding your money until it confirms the numbers (the official explainer is at Understanding your CP05 notice).
The review is automated. A computer flagged something on your return that the IRS wants to match against its own records before it pays out. That doesn't mean you did anything wrong — it means the system wants to verify before it writes the check.
One thing a CP05 is not: an audit, and not a bill. Nobody is asking you to pay. The IRS is simply pressing pause on your refund.
Why the IRS is reviewing your return
The IRS doesn't always spell out the exact trigger, but a CP05 review almost always involves checking one or more of these:
- Income and withholding. The IRS compares the wages and federal tax withheld on your return against the W-2s and 1099s your employers and banks reported. If the totals don't match yet — or an employer filed late — the refund waits.
- Tax credits. Refundable credits like the Earned Income Tax Credit and the Additional Child Tax Credit get extra scrutiny because they're a common target for fraud.
- Identity. Sometimes a refund hold is really about confirming the return was filed by you. If that's the concern, you'll typically get a separate identity letter — see our guide to the 5071C identity verification letter if that's what landed in your mailbox.
In plain terms: the IRS is making sure the refund goes to the right person for the right amount. If everything lines up, the money is released.
What happens next — and what could delay it
Here's the realistic sequence after a CP05 lands:
- CP05 arrives. Refund is held. No action needed from you. The 60-day clock starts on the notice date.
- The IRS verifies internally. Most reviews finish here. If the numbers match, your refund is released — sometimes within a few weeks.
- CP05A (only if needed). If the IRS can't confirm something on its own, it sends a CP05A asking for specific documents — pay stubs, W-2s, or proof of a credit. This notice has a deadline. Respond on time with copies, never originals.
- Refund released or adjusted. Once the review closes, you either get the full refund (often with interest if the hold ran long) or an adjusted amount with a separate notice explaining the change.
The biggest cause of delay in 2025 is simple: the IRS is processing reviews with reduced staff, so a 60-day window can stretch longer. The hold itself is routine — the wait is what tests your patience.
Do you need to respond to a CP05?
For a standard CP05, no. The notice asks for nothing, and sending unsolicited documents won't speed the review — it can actually slow it by adding paperwork to your file. Wait unless the IRS specifically asks.
You should act if any of these are true:
- You received a CP05A requesting documents — respond by its deadline.
- You know something on your return was wrong — it's better to fix it than wait for the IRS to find it.
- It's been more than 60 days with no refund and no further notice.
- You're facing real financial hardship because the refund is delayed.
How to respond, step by step
- Confirm the notice is real. A genuine CP05 comes by postal mail, never email or text. The IRS won't ask for payment or threaten you over a refund review. If something feels off, check our guide on how to tell if an IRS letter is real.
- Check your IRS online account. Log into your IRS online account and pull your account transcript. It often shows hold and review codes before any letter arrives — our walkthrough on how to read an IRS account transcript shows you what to look for.
- Compare your return to your records. Make sure the income and withholding you reported match your W-2s and 1099s. If you spot a mistake, plan to amend.
- Wait if no documents were requested. A plain CP05 needs nothing from you. Mark 60 days from the notice date on your calendar.
- If a CP05A asks for documents, send clear copies by the deadline and keep your own copy of everything you mail or upload.
- If 60 days pass with silence, call the IRS, or reach out to the Taxpayer Advocate Service — especially if the delay is causing hardship.
Refund stuck under a CP05 review?
Send us a photo of your notice. An experienced tax professional will read your transcript, tell you exactly why the IRS is holding your refund, and map out the fastest path to release it — free, confidential, no pressure.
CP05 questions, answered
How long does a CP05 review take?
The IRS gives itself up to 60 days from the date on the CP05 to finish the review and release or adjust your refund. Many cases close sooner, but some take longer — especially if the IRS sends a follow-up CP05A asking for documents. If 60 days pass with no update, you can call the IRS or contact the Taxpayer Advocate Service.
Do I need to do anything when I get a CP05?
Usually not. A plain CP05 asks for nothing — you just wait while the IRS verifies your income, withholding, and credits. Only respond if the notice or a follow-up CP05A specifically requests documents. Sending unsolicited paperwork won't speed things up and can confuse your file.
Does a CP05 mean I'm being audited?
No. A CP05 is a refund review, not an audit. The IRS is matching what you reported against W-2s, 1099s, and other records before it releases your money. Most CP05 reviews end with the refund being paid in full once the numbers check out.
Why is the IRS holding my refund with a CP05?
The IRS flagged something it wants to confirm before paying — usually wage and withholding amounts, tax credits like the Earned Income Tax Credit, or whether an employer has reported matching information. The hold is a verification step, not an accusation. If everything matches, the refund is released.
Will I still get interest if my refund is delayed by a CP05?
Often yes. If the IRS holds a refund past the legal window after your return was filed on time, it generally must pay interest on the delayed amount. You don't have to request it — any interest owed is added automatically when the refund is released, and it's taxable income the following year.
This guide is general information, not tax or legal advice for your specific situation. Eligibility for IRS programs depends on individual facts and circumstances; no outcome is guaranteed.