Beginning January 1, 2026, the IRS increased the reporting threshold for research participant payments from $600 to $2,000 per calendar year. This amount may change annually.
Who should read this notice?
Research teams with studies that involve participant payment.
What do I need to do?
| Study Status | Guidance |
|---|---|
| If you are submitting a new study | Use the updated consent form template language in Section 9 (Payment) of the ICF Companion Document. |
| If your study is currently enrolling | At your next modification, update the payment section in your consent form. Use the language in Section 9 (Payment) of the ICF Companion Document. |
| If your study is no longer enrolling | No action required. |
Do I need to reconsent participants?
No. This threshold increase is not a change that requires reconsent because this information would not likely affect a participant’s willingness to continue in the study.
Study teams, at their discretion, may verbally inform participants of the threshold increase or provide them with a handout. Please see below for IRB-approved language. Note:
- You may add study-specific details (e.g., PI name, study title, study number, etc.) when communicating the approved statement to participants. If these are the only additions to the notification, do not submit this communication plan to the IRB for review and approval.
- Any other changes or information added to the IRB-approved language will require IRB review and approval via a Modification Form.
Approved language:
Beginning January 1, 2026, the IRS increased the reporting threshold for research participant payments. You previously signed a consent form stating that the IRS must be notified when payments reach $600 per year. This threshold is now $2,000 and may change from year to year.