Every valid missing-TIN reason code (000222111 through 999999999), the precedence rules that govern them, and how the Novus AI Validation Engine enforces them at the row level.
Under FATCA, FFIs are generally required to report the US Taxpayer Identification Number (TIN) of every account holder who is a specified US person. In practice, some accounts cannot obtain a TIN despite the FFI's best efforts — the account holder is unresponsive, the account is dormant, or the only US indicia is a US place of birth.
To address this, the IRS permits FFIs to report a Missing TIN Reason Code in place of the TIN. Each code corresponds to a specific scenario, and the IRS applies strict eligibility and precedence rules. Using the wrong code — or the right code at the wrong precedence — triggers schema validation failures.
AAAAAAAAA and 000000000 strings are no longer accepted.
| IRS Relief Code | Account Classification | Official IRS Usage Criteria | Precedence & XML Rules | How Novus AI Validates It |
|---|---|---|---|---|
000222111 |
Pre-existing Depository Individual | Only US indicia is a US place of birth, AND FFI determined from AML/KYC records that the account holder is a tax resident of the local jurisdiction. | Priority 1 (Highest): Overrides all other codes. Requires <BirthDate> in XML. |
Verifies <BirthDate> presence and ensures account is an Individual record. |
222222222 |
Pre-existing Individual | Only US indicia is a US place of birth (and the local tax residency requirement for 000222111 is not met). |
Priority 2: Overrides all codes except 000222111. Requires <BirthDate>. |
Flags a hard error if <BirthDate> is empty or if used on an Entity record. |
333333333 |
New Individual Account | Has indicia of a US place of birth, AND either had a change in circumstances invalidating the original self-cert, OR exceeded threshold after opening. | Applies strictly to New Individual accounts. Requires <BirthDate>. |
Cross-checks account lifecycle status and enforces mandatory <BirthDate> tag. |
444444444 |
Pre-existing Individual or Entity | Has US indicia other than US place of birth, AND had a change in circumstances or exceeded reporting threshold after initial review. | Valid for both <Individual> and <Organisation> pre-existing accounts. |
Validates code against <AccountHolderType> and account opening date logic. |
555555555 |
New Individual or Entity | Has US indicia other than US place of birth, AND had a change in circumstances invalidating the self-cert or exceeded threshold after opening. | Valid for both <Individual> and <Organisation> new accounts. |
Flags row-level warning if applied to a pre-existing account. |
666666666 |
Pre-existing Entity (Passive NFFE) | Account held by a Passive NFFE with one or more Controlling Persons where self-certs were not obtained and no US indicia were identified. | Entity Only: Strictly restricted to <Organisation> accounts. |
Blocks XML export if 666666666 is accidentally assigned to an Individual account. |
777777777 |
Dormant Account | Pre-existing account above threshold meeting the Dormant Account definition (no financial activity for 3 years, no contact for 6 years). | Lowest Specific Precedence: Use codes 000222111–666666666 first if multiple apply. |
Checks if higher-precedence birth-place codes apply before allowing 777777777. |
999999999 |
Catch-All / Good Faith | Any account where the FFI cannot obtain a TIN despite annual solicitation and electronic search, and none of the specific codes above apply. | Fallback relief code replacing legacy AAAAAAAAA or 000000000 strings. |
Automatically flags and upgrades legacy AAAAAAAAA or 000000000 entries during import. |
When more than one relief code could apply to an account, the IRS requires you to report the highest-precedence code. The order is:
000222111 — Highest priority222222222333333333444444444555555555666666666777777777 — Lowest specific priority999999999 — Fallback only<BirthDate>, (2) their Foreign TIN (FTIN) if present in electronically searchable records, and (3) their City and Country of Residence. Always set the XML attribute to <sfa:TIN issuedBy="US">.
999999999 for every missing TIN. This is only valid when none of the other codes apply. Misusing the catch-all code is the most common cause of IRS rejection for missing-TIN filings.
No. 999999999 is a fallback only. It is valid only when none of the specific scenario codes (000222111 through 777777777) apply to the account.
IDES will reject the file with a schema validation failure. Codes 000222111, 222222222, and 333333333 all require the <BirthDate> element to be populated.
Yes — and only entity accounts can use it. Code 666666666 applies specifically to pre-existing Passive NFFEs where controlling person self-certs were not obtained and no US indicia were identified.
The AAAAAAAAA string is no longer valid. If your system produces it, Novus AI automatically flags and upgrades it to 999999999 during import.