
Dealers are allowed to submit time-of-sale reports for transactions that occurred before 2024, but with some specifics and recent developments regarding the process:
- Dealers can submit corrected time-of-sale reports for transactions that occurred more than 3 calendar days from the date of sale, indicating some flexibility in submitting reports after the initial deadline.
- Registered dealers may submit time-of-sale reports for both new and previously owned vehicle sales, regardless of the exact timing, as long as they are licensed by a state.
- For transactions in 2024, the IRS reopened the time-of-sale reporting portal starting March 2025 to allow submission of qualifying clean vehicle credit transactions that were not filed timely during the year, indicating the IRS’s willingness to accept delayed reports within the same calendar year at least.
- Crucially, starting December 10, 2024, the IRS enabled dealers to submit previously unsubmitted required time-of-sale information through the Energy Credits Online (ECO) Tool for any 2024 transaction not previously submitted. This relief helps dealers who missed the original 3-day submission window for 2024 sales and encourages immediate submission to avoid processing delays.
However, there is no explicit indication in the available information that dealers can submit time-of-sale reports for transactions that occurred before 2024. The emphasis in the IRS communications and relief efforts is on 2024 transactions, with no mention of reopening or allowing submissions for transactions from earlier years.
Summary:
- Dealers can submit or correct time-of-sale reports for 2024 transactions even after the original deadline, using the IRS ECO Tool as of December 10, 2024, and through reopened portals in 2025.
- Dealers can submit time-of-sale reports for new and used vehicles they have sold (licensed dealers), but the relief and reopening applies specifically to 2024 transactions.
- There is no clear provision allowing dealers to submit time-of-sale reports for transactions that occurred before 2024.
Therefore, the answer is: Dealers cannot submit time-of-sale reports for vehicle transactions that occurred before 2024 under the current IRS provisions; the reporting and relief efforts apply only to 2024 transactions and forward.
Original article by NenPower, If reposted, please credit the source: https://nenpower.com/blog/can-dealers-submit-time-of-sale-reports-for-transactions-that-occurred-before-2024/
