IRS Form 15320 Guide: Security Summit Member Application

ARUN KP

10/17/2026

1. Introduction: What is Form 15320?

IRS Form 15320, officially titled Application for Security Summit Membership, is an administrative partnership application published by the Internal Revenue Service (IRS). It is governed by the National Public Liaison (NPL) office within the IRS Communications and Liaison (C&L) Division under OMB Control Number 1545-2295.

This form is not an individual or corporate tax return. Instead, Form 15320 is a specialized institutional application used by organizations operating within the tax ecosystem—including state revenue departments, tax software developers, financial institutions, payroll reporting agents, and national professional associations. It serves as the official gateway for eligible entities to apply for formal membership in the Security Summit, an unprecedented public-private partnership dedicated to combating tax-related identity theft and cyber fraud.

2. Purpose of the Form: Why Does Form 15320 Exist?

In 2015, the IRS, state tax agencies (through the Federation of Tax Administrators), and the private-sector tax community established the Security Summit in response to an alarming rise in stolen identity refund fraud (SIRF) and sophisticated cyberattacks. Modern cybercriminal syndicates target tax preparation software, payroll databases, and electronic filing platforms to steal taxpayer data and submit fraudulent tax returns.

Because no single organization can defend the national tax infrastructure alone, the Security Summit allows government agencies and industry leaders to collaborate, share real-time threat intelligence, and standardize cybersecurity defenses. Form 15320 exists to manage and govern this vital coalition:

  • Vetting Industry Partners: It serves as a formal screening mechanism to evaluate the mission, operational responsibilities, and cybersecurity maturity of organizations applying to join the coalition.
  • Securing Executive Commitment: It requires executive-level leadership to commit the organization’s resources, technical expertise, and threat telemetry to national anti-fraud working groups.
  • Facilitating Threat Intelligence Sharing: Approved members gain access to collaborative platforms, such as the Identity Theft Tax Information Sharing and Analysis Center (ISAC), allowing rapid communication of emerging phishing schemes, system breaches, and fraudulent return patterns.

3. Who Needs to File This Form?

Form 15320 is completed by organizations, government agencies, and businesses that play a functional role in the federal and state tax ecosystem. You need to complete Form 15320 if your organization is seeking official membership in the Security Summit under one of the following categories:

  • State and Municipal Tax Agencies: State departments of revenue, state tax commissions, or municipal tax authorities administering income taxes.
  • Software Developers & EROs: Commercial tax software vendors, online tax filing platforms, and high-volume Electronic Return Originators (EROs).
  • Financial Services Institutions: Commercial banks, prepaid debit card issuers, payment processors, and financial technology companies that disburse tax refunds or handle tax payments.
  • Payroll Reporting Agents: Payroll service bureaus, human capital management software providers, and reporting agents managing employment tax withholdings.
  • Endorsing Organizations: Major national tax professional associations (such as the AICPA, NAEA, or NATP) representing CPAs, enrolled agents, and tax preparers.

4. Who Is Exempt / Not Required to File?

Because Form 15320 is an institutional partnership application, large segments of the public and individual tax professionals do not use it:

  • General Individual Taxpayers: Everyday citizens, wage earners, and students managing personal income taxes never complete Form 15320.
  • Commercial Businesses Outside the Tax Sector: General retail, manufacturing, and commercial companies that do not provide tax, payroll, or financial settlement services are ineligible for membership.
  • Individual Tax Practitioners: Solo CPAs, individual enrolled agents, and small local accounting firms do not apply individually; they are represented in the Security Summit through their national professional endorsing associations.
  • Current Active Summit Members: Organizations that have already been vetted and maintain active standing in the Security Summit do not need to reapply unless requested during a periodic governance review.

5. When to File: Deadlines and Frequency

Form 15320 is an event-based application document rather than an annual recurring filing. Organizations can submit the application at any point during the calendar year.

However, prospective member organizations should submit Form 15320 well in advance of upcoming tax filing seasons or scheduled Security Summit working group sessions. Applying in the spring or summer allows the IRS National Public Liaison team and the Summit steering committee adequate time to review credentials, verify references, and onboard executive and technical representatives before peak filing season cyber defenses are activated.

6. Where and How to File

Form 15320 cannot be submitted through standard electronic tax return filing software. The IRS provides dedicated administrative channels to submit your application:

  • Submission by Facsimile (Recommended): Complete and sign the paper Form 15320 and fax it directly to the dedicated IRS National Public Liaison fax number at 855-811-8020. Always retain your transmission confirmation report.
  • Submission by Mail: Mail the original completed, signed application to the designated IRS address as per instructions (specifically: Internal Revenue Service, National Public Liaison, Room 7559 CL:NPL, 1111 Constitution Ave, NW, Washington, DC 20224).
  • Senior Executive Signature Required: The application must be signed by the Head of Agency, Chief Executive Officer (CEO), Chief Operating Officer (COO), or an authorized Senior Executive. Applications signed by unauthorized staff will be rejected.

7. Step-by-Step Instructions to Fill Form 15320

Form 15320 captures organization baseline data, category classification, contact details, operational mission, and executive endorsements. The table below outlines each primary section of the form.

Section Item Name Required Information & Standards
Part I Applicant Details Legal organization name, trade name (DBA), Employer Identification Number (EIN), and headquarters address.
Part II Membership Category Selection of organization category: State/City, Software/ERO, Financial, Payroll, Endorsing, or Other.
Part III Key Contacts Names, titles, direct phone numbers, and professional email addresses for primary and secondary contacts.
Part IV Mission & Role Narrative description of the organization’s functional responsibilities within the national tax ecosystem.
Part V Contributions & Goals Explanation of expected contributions to Summit working groups and benefits anticipated from membership.
Part VI Executive Signature Original signature of the Head of Agency, CEO, or Senior Executive, title, and execution date.

Part I: Organization Information

Enter the complete legal name of the organization exactly as chartered or registered with state and federal authorities. If operating under a commercial trade name or “doing business as” (DBA) name, provide that detail. Enter your nine-digit Employer Identification Number (EIN), corporate headquarters address, and primary organizational website.

Part II: Membership Category Selection

Select the single membership category that most accurately describes your organization’s primary function in the tax administration system:

  • State/City Tax Agency
  • Software Developer / Electronic Return Originator (ERO)
  • Financial Services
  • Payroll Reporting Agents
  • Endorsing Organization (Tax Professional Association)
  • Other (requires a specific written description of your technology or security function)

Part III: Primary and Secondary Contact Information

Provide contact details for two key representatives who will serve as operational liaisons between your organization and the Security Summit. The Primary Contact is typically an executive or policy leader who attends governance briefings, while the Secondary Contact is often a technical chief information security officer (CISO) or cybersecurity director who interfaces with technical working groups and the ISAC threat feed.

Parts IV and V: Mission, Responsibilities, and Contributions

This is the core narrative evaluation section of Form 15320. You must provide clear, concise descriptions of:

  • Functional Role in the Tax Ecosystem: Explain what services your company provides, such as filing millions of electronic returns, processing payroll for thousands of employers, issuing tax refund debit cards, or representing certified tax professionals.
  • Anticipated Contributions: Detail how your organization will contribute to Summit goals (e.g., sharing threat telemetry, implementing advanced multi-factor authentication, testing anti-fraud algorithms, or conducting educational outreach to practitioners).
  • Expected Benefits: Describe how membership will help your organization enhance internal data security and better protect your customers or constituents.

Part VI: Senior Executive Execution

The application concludes with an attestation statement. The Head of Agency, Chief Executive Officer, or Senior Executive must sign, date, and print their official title. By signing, the executive certifies that the organization is committed to supporting Security Summit initiatives and adhering to all data protection and confidentiality standards.

8. Required Documents and Information Needed Before Filling

Before preparing Form 15320, compile the following institutional records:

  • Your organization’s official Employer Identification Number (EIN) and corporate governance details.
  • An overview of your company’s data protection architecture, cybersecurity framework, and volume of tax-related transactions handled annually.
  • Direct contact details for your primary executive liaison and technical cybersecurity lead.
  • A written summary of your organization’s willingness to participate in specific Security Summit working groups (such as Authentication, Financial Services, or Communications).
  • Sign-off from your agency head or corporate executive leadership.

9. Common Mistakes to Avoid

Errors on Form 15320 can delay processing or result in application denial by the steering committee. Watch out for these frequent mistakes:

  • Unauthorized Signatures: Submitting an application signed by an outside consultant, legal counsel, or mid-level IT manager will cause the IRS to reject the form. It must be signed by the Head of Agency, CEO, COO, or a designated Senior Executive.
  • Providing Vague or Generic Narratives: Writing broad statements like “we want to fight fraud” without detailing your specific operational volume, software capabilities, or data assets provides evaluators with no basis to approve membership.
  • Submitting as an Individual Tax Preparer: Form 15320 is for institutional and organizational membership. Individual practitioners should join through professional associations like the NAEA, NATP, or state CPA societies.
  • Failing to Provide a Secondary Technical Contact: The Security Summit relies heavily on rapid technical data sharing during filing season. Omitting a dedicated technical contact slows down vetting.
  • Sending to General Tax Processing Centers: Form 15320 must be faxed or mailed directly to the IRS National Public Liaison office in Washington, DC, as indicated in the instructions.

10. Penalties for Non-Filing or Errors

Because Form 15320 is a voluntary partnership application rather than a tax return, there are no civil tax fines for not filing it. However, procedural and legal rules apply:

  • Ineligibility for Threat Feeds: Non-member organizations cannot participate in Security Summit working groups or access the real-time cyber threat indicators distributed through the Tax ISAC.
  • Application Denial: Submitting incomplete or unverified applications results in formal denial by the IRS and the Summit steering committee.
  • Expulsion for Breach of Standards: Member organizations that fail to maintain required data security baselines, misuse shared threat data, or violate confidentiality agreements are subject to immediate expulsion from the Summit.
  • Federal False Statement Penalties: Knowingly providing fraudulent corporate information on an official application submitted to the federal government is punishable under 18 U.S.C. Section 1001.

11. Related Forms or Schedules

Form 15320 operates alongside a specialized suite of IRS data security publications and electronic filing forms:

  • IRS Publication 4557: Safeguarding Taxpayer Data – A Guide for Your Business (the foundational security manual for tax industry participants).
  • IRS Publication 5293: Data Security Resource Guide for Tax Professionals.
  • Form 8633: Application to Participate in the IRS e-file Program.
  • Form 2848: Power of Attorney and Declaration of Representative.
  • NIST Cybersecurity Framework: National Institute of Standards and Technology standards referenced across Security Summit protocols.

12. Frequently Asked Questions (FAQs)

1. What is the IRS Security Summit?

The Security Summit is a collaborative public-private coalition formed in 2015 between the IRS, state tax agencies (through the Federation of Tax Administrators), and the private-sector tax industry (software developers, banks, payroll companies, and tax associations) to combat tax-related identity theft and refund fraud.

2. Can an individual tax preparer apply for membership using Form 15320?

No. Form 15320 is designed for organizations, corporations, state agencies, and professional associations. Individual tax preparers participate in Security Summit initiatives and receive guidance through their software vendors and national endorsing organizations.

3. Is there a government fee to apply for Security Summit membership?

No. The IRS does not charge an application fee or annual membership dues to apply for or maintain membership in the Security Summit.

4. What are the primary benefits of joining the Security Summit?

Approved members collaborate directly with IRS leadership, participate in specialized anti-fraud working groups, help shape national cybersecurity standards, and gain access to rapid threat intelligence feeds through the Tax ISAC to protect their systems from emerging cyberattacks.

5. Who must sign Form 15320?

The application must be signed by the organization’s Head of Agency or a Senior Executive, such as the Chief Executive Officer (CEO), Chief Operating Officer (COO), or President, confirming executive-level commitment to the coalition’s security objectives.

6. How long does the application review process take?

Applications are reviewed by the IRS National Public Liaison team and the Security Summit steering committee. Processing and background verification typically take 30 to 60 days, after which the primary contact is notified in writing regarding membership status.

13. Conclusion: Key Takeaways

IRS Form 15320 is the official gateway for tax and financial organizations to join the nation’s frontline defense against tax fraud and identity theft. By uniting state agencies, commercial software vendors, payroll processors, and financial institutions under the Security Summit, the coalition protects hundreds of billions of dollars in taxpayer funds each year.

Because membership requires an executive commitment to collaboration, data security, and active participation, applicant organizations should clearly articulate their operational role, ensure Form 15320 is executed by a senior executive, and submit the completed application via fax or certified mail to the IRS National Public Liaison office.

ARUN KP
Author

Entrepreneur | Tax Journalist | India-US Tax Consultant & Professional Accountant. Connect with me on LinkedIn.

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