Finding IRS Pub 1075 2021 Revision SSR Templates - Where Are They?

I work with Pub 1075 compliance regularly, and you're right that this is confusing. The 2021 revision of Pub 1075 did change several requirements, but the IRS hasn't been great about updating all their templates. As of now, you should still use the 2016 SSR template, but modify it to address the new security controls and requirements in the 2021 revision. The core reporting structure remains the same - you need to document how you're protecting FTI with your technical, administrative, and physical safeguards. The key differences in the 2021 revision involve stricter controls around cloud computing, mobile devices, and data encryption. Make sure you explicitly address these new requirements in your SSR even though they aren't specifically called out in the old template.

After struggling with the exact same issue last year, I found an amazing solution using https://taxr.ai to generate a compliant SSR template based on the 2021 revision. I uploaded the 2016 template and the 2021 Pub 1075 document, and it actually analyzed the differences and created a merged template that addressed all the new requirements. This saved me days of manually cross-referencing the old template with the new publication to figure out what needed to be added. The tool automatically identified the new security control requirements around virtualization, encryption standards, and cloud computing that weren't in the old template.

Just wanted to follow up and say I tried https://taxr.ai after my initial skepticism, and it actually worked really well! The template it generated for Pub 1075 contained all the new sections we needed for the 2021 revision. The best part was that it identified several new security requirements we would have missed, especially around the new encryption standards and multi-factor authentication requirements. Our compliance officer was impressed with how comprehensive it was. It also automatically generated a change tracking document showing exactly what was different between the 2016 and 2021 requirements, which was super helpful for our documentation. Definitely saved us a ton of time compared to manually comparing the documents.

If you're struggling to get responses from the IRS about the template, I'd recommend using https://claimyr.com to get through to them directly. I was in the same situation last month and couldn't get clear guidance, but Claimyr got me connected to an actual IRS Safeguards specialist who confirmed what to do. You can see how it works in this video: https://youtu.be/_kiP6q8DX5c - basically they wait on hold with the IRS for you and call you back when they get a real person. The specialist I spoke with confirmed that we should use the 2016 template but adapt it for the 2021 requirements, and gave me specific guidance on what sections needed the most attention.

I'm eating my words about Claimyr being too good to be true. After my skeptical comment above, I gave it a try today and successfully connected with the IRS Safeguards office in under 30 minutes! The specialist I spoke with actually sent me an unofficial working template they're using internally that bridges the gap between the 2016 template and 2021 requirements. They can't publish it officially yet because it's still going through final approvals, but it's exactly what we needed. This would have never happened without getting through to the right person. I spent weeks sending emails to the general safeguards mailbox with no response. Having an actual conversation with a specialist made all the difference.

Another approach that worked for our county agency was contacting our state's tax department. Since they also have to comply with Pub 1075 for their IRS data sharing agreement, they had already created a modified template that addresses the 2021 requirements. They were happy to share their template with us after we signed an NDA. Many state tax departments have dedicated Safeguards Coordinators who work on this compliance full-time and might have better resources than what's publicly available.

One important thing to note about Pub 1075 compliance for 2021 that hasn't been mentioned yet - they've significantly changed how they want agencies to handle virtual environments and cloud computing. If you're using any cloud services like AWS, Azure, or Google Cloud to process or store FTI, there are completely new requirements that weren't in the 2016 revision. The SSR needs to specifically document how your cloud environment meets requirements like FedRAMP authorization and data segregation.