What are FATCA Missing TIN Relief Codes?
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.
Complete Missing TIN Relief Codes (2026/2027)
| IRS Relief Code | Account Classification | Official IRS Usage Criteria | Precedence & XML Rules | How Novus 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. |
Flags legacy AAAAAAAAA or 000000000 entries during import, so you can replace them with the right code. |
Precedence Rules — Which Code Wins?
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
Frequently asked questions
Can I use code 999999999 for every missing TIN?
No. 999999999 is a fallback only. It is valid only when none of the specific scenario codes (000222111 through 777777777) apply to the account.
What happens if I use 000222111 without providing a BirthDate?
IDES will reject the file with a schema validation failure. Codes 000222111, 222222222, and 333333333 all require the <BirthDate> element to be populated.
Can an entity account use code 666666666?
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.
What about the legacy AAAAAAAAA code?
The AAAAAAAAA string is no longer valid. If your system produces it, Novus flags it during import so you can replace it with the correct code, which is 999999999 only when no specific code applies.