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REVENUE PROCEDURE · 2026-08

Rev. Proc. 2026-08 — Current Automatic Consent Changes List

The 2026 update to the annual Revenue Procedure listing accounting method changes eligible for automatic consent under Rev. Proc. 2015-13. Rev. Proc. 2026-08 carries forward the cost-segregation-relevant Designated Change Numbers (including DCN 7 for impermissible-to-permissible depreciation method changes) and adds OBBBA-related §168(k) elections.

Rev. Proc. 2026-08 is the 2026 edition of the annual Revenue Procedure listing accounting method changes eligible for automatic consent under the framework of Rev. Proc. 2015-13. The IRS issues a new list each year to add, remove, or modify the Designated Change Numbers (DCNs) that taxpayers may use without seeking a private letter ruling.

The annual list is the document a Form 3115 preparer consults first before filing — it confirms whether the change being requested is on the current automatic-consent menu, what the operative DCN is, and whether any procedural conditions have been modified. Filing under an obsolete DCN or under a DCN that has been removed from the current list forfeits automatic consent.

Editorial note. The exact §-citations and verbatim text of Rev. Proc. 2026-08 are being verified against the issued IRB before quotation here. Practitioners should confirm the current DCN list against the most recent IRB cumulative bulletin or the IRS’s online List of Automatic Changes. The descriptions below summarize the procedural framework as it has operated under prior annual list procedures (2015-14, 2017-30, 2019-43, 2022-14, etc.).

What it generally addresses

The annual list traditionally is organized by Code section. Cost segregation practitioners care primarily about three sections:

  • Section 6 — Depreciation, Amortization, and Disposition (§§ 167, 168, 197, 263). This section enumerates the DCNs available for depreciation method changes. DCN 7 — impermissible-to-permissible depreciation method change — is the DCN under which cost segregation §481(a) catch-up filings are made.
  • Section 6 — §168(k) Bonus Depreciation Elections. Successive annual list procedures have added DCNs for late §168(k) elections, late elections out of bonus, and revocations. The OBBBA 2025 restoration of 100% bonus depreciation has driven additions to the bonus-election DCN family for transition mechanics.
  • Section 7 — Capitalization (§ 263A). UNICAP-related method changes that interact with self-constructed cost segregation property.

How it operates

A Form 3115 preparer uses the annual list in three operations:

  1. Confirm eligibility. Look up the type of change being requested in the current annual list. If the change is enumerated and the taxpayer meets the eligibility conditions in the procedure’s general rules, automatic consent is available.
  2. Identify the DCN. The annual list assigns a Designated Change Number to each automatic-consent change. The DCN is reported on Form 3115 Part I; it is the IRS’s index entry for the change. For cost segregation catch-up filings, DCN 7 has been the operative number across multiple annual list updates.
  3. Apply the conditions. Each DCN has procedural conditions — eligibility, computation rules, and audit-protection scope. The annual list specifies the conditions for the current year; deviations forfeit consent.

Cross-references

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