Understand the WOTC Hiatus.
Stay Compliant. Stay Prepared.
Beginning January 1, 2026, the Work Opportunity Tax Credit enters a legislative hiatus. The program remains operational, and applications continue to be submitted and processed. This orientation explains what employers need to know — clearly and confidently.
- What changes during the hiatus — and what does not
- How “on-hold” status actually works behind the scenes
- Employer actions required to protect credit eligibility
Presented by McKenzie Chase Management (MCM)
What the WOTC Hiatus Means for Employers
The WOTC program does not end during a hiatus. Instead, it enters a temporary authorization gap with specific operational changes. Understanding this distinction is critical to protecting eligibility.
December 31, 2025
WOTC remains fully authorized. All eligible hires in 2025 are processed normally and remain eligible for credits under current rules.
January 1, 2026
WOTC enters a legislative hiatus. State agencies continue to receive and timestamp applications, but pause issuing approval notifications.
Congressional Action
Once Congress renews the program, approval notices are released and credits are calculated — often retroactively.
What Changes During the Hiatus
- Approval notifications are temporarily paused
- Credits cannot be claimed until reauthorization
- Applications may show an “on-hold” status
What Continues Without Interruption
- WOTC Forms must still be submitted within 28 days
- State agencies continue reviewing and processing applications
- Internal approvals occur in most states
- Employer eligibility is preserved
Key takeaway:
A WOTC hiatus pauses approval notifications — not the program itself.
Employers who continue timely filings protect their eligibility.
Employers who pause introduce unnecessary risk.
What “On-Hold” Really Means
Many employers are seeing an “on-hold” status for WOTC applications. Here’s the clear, accurate explanation — without the confusion.
❌ What “On-Hold” Does NOT Mean
- Your application has been denied or rejected
- Processing or review has stopped
- Your WOTC provider paused submissions
- You’ll need to refile after renewal
✅ What “On-Hold” Actually Means
- Applications continue to be submitted and accepted by state agencies
- State WOTC agencies continue reviewing and working cases
- Most states internally approve applications during the hiatus
- Only approval notifications are temporarily paused
- Credit eligibility is fully preserved
Key takeaway: Applications submitted during the hiatus remain valid, continue through the normal review process, and do not require re-filing once Congress renews the program.
WOTC Hiatus: Facts vs. Myths
During a hiatus, misinformation spreads quickly. Here’s what’s actually happening — and what’s not.
WOTC applications continue moving through review and processing during the hiatus.
Processing stops entirely until Congress renews the program.
Employers should continue submitting WOTC Forms within 28 days of hire.
WOTC filings should be paused until legislation passes.
An “on-hold” status only pauses approval notifications — not application review.
Applications marked “on-hold” are delayed, denied, or inactive.
No re-filing is required once Congress renews the WOTC program.
Employers must resubmit all hiatus-period applications.
Congress has renewed the WOTC program repeatedly for nearly 30 years — often retroactively and with bipartisan support.
The current hiatus signals the end of the WOTC program.
Bottom line: Employers who continue timely WOTC filings preserve eligibility. Pausing activity creates risk — legislative timing does not.
Required Employer Actions During the Hiatus
To preserve full WOTC eligibility, employers should continue operating exactly as they did before the hiatus.
Continue WOTC Screening for Every New Hire
Screening questions must remain part of your onboarding process without interruption.
Submit WOTC Forms Within 28 Days
Timely submission is required by law and preserves eligibility for retroactive credits.
Keep Your WOTC Workflow Unchanged
Do not pause, delay, or alter your hiring or WOTC submission process.
Verify Your WOTC Provider Is Still Submitting
Ensure applications are filed and timestamped with state agencies within required timeframes.
Maintain Accurate New Hire Documentation
Complete and retain all required onboarding records for compliance and audit readiness.
Prepare for Retroactive Certifications
Once Congress renews WOTC, approval notices will be released without re-filing.
Key message: Delays or pauses in filing create risk. Legislative timing does not.
What to Expect When WOTC Is Renewed
Once Congress renews the program, the transition back to approvals is structured, predictable, and does not require action from employers who filed correctly.
Congressional Renewal Is Passed
Congress authorizes the next WOTC period, typically including retroactive coverage for hires made during the hiatus.
State Agencies Release Approval Notifications
Applications previously marked “on-hold” receive official approval notifications. No re-filing or resubmission is required.
Surge in Certifications and Credit Calculations
Certified applications are released in volume, and eligible credits are calculated for qualifying hires.
Employers Claim Credits Through Normal Tax Filing
Credits are applied using standard tax forms and processes, just as in non-hiatus years.
Important: Employers who continued timely filing during the hiatus experience a smooth transition once approvals resume — without delays, rework, or lost credits.
Book Your WOTC Hiatus Check-In
Whether you’re an existing client or exploring WOTC for the first time, this session ensures you understand exactly what’s happening, what continues, and how to protect eligibility during the hiatus.
- Clarify how the WOTC hiatus affects your organization
- Confirm your current filing and compliance status
- Learn what continues behind the scenes during the hiatus
- Prepare for retroactive certifications once WOTC is renewed
No obligation. No sales pressure. Just clear guidance during legislative uncertainty.
Schedule Your Session
Choose a time that works for you. We’ll walk through the hiatus, answer questions, and outline next steps tailored to your organization.
Book WOTC Hiatus Check-In