As part of the fiscal year 2026-2027 budget (A10009/S09009), New York has enacted a mandatory sales tax vendor reregistration program.

Under existing law, the Department of Taxation and Finance (the Department) has authority to require vendors holding a Certificate of Authority (COA) to renew their registrations. This enables the Department to update taxpayer information and collect past-due taxes.

The new program specifically mandates that a reregistration of all vendors be completed by Dec. 31, 2030.

Overview

Phased approach: Vendors cannot self‑initiate reregistration. Instead, each vendor must wait until it is selected by the Department and receives a formal expiration notice. The Department will mail a notice by certified mail at least 180 days before a vendor’s COA expiration date. Vendors must submit a complete reregistration application at least 90 days before the stated expiration date.

Once a complete application is filed, the Department has 30 days to approve a new COA or deny the renewal. If the renewal is denied, vendors can request an expedited hearing to contest the denial.

Reregistration is not automatic: Vendors must be in full compliance to obtain a new COA. This includes updating business information and resolving outstanding tax liabilities.

Penalty and interest discount program: To incentivize compliance, the new legislation also creates an opportunity for vendors to receive a 100% penalty abatement and a 50% interest deduction for outstanding sales and use tax liabilities paid in full by Dec. 31, 2026.

To be eligible for the program, the liabilities must be “fixed and final” (meaning, the vendor no longer has the right to appeal) by Sept. 1, 2026, and must not be related to fraud or previous compromises by the Department.

The Department will notify vendors with eligible liabilities of the discounted amount due under the program.

What does CohnReznick think?

The reregistration program gives vendors a practical opportunity to confirm that their records are current, including business addresses, contact information, and responsible-person designations. Vendors with outstanding sales and use tax liabilities should also evaluate whether they may be able to take advantage of the penalty abatement and interest reduction available for qualifying liabilities paid by Dec. 31, 2026.