How to Win Back Tax Clients Without Violating Section 7216

Every tax firm has them: clients who filed with you once or for years and then quietly disappeared. Maybe they moved. Maybe they tried DIY software. Maybe life just happened.

It’s worth reconnecting. But before you export a list from your tax software and send a promotion, there’s one rule you need to understand: Section 7216.

Start with what you’re actually allowed to use

Tax return information is confidential, and that includes certain information you collected while preparing returns. Under the Section 7216 regulations, a limited client list may generally be used without separate consent to solicit tax return preparation services and provide qualifying educational information.

That doesn’t mean your old tax client list is fair game for every offer. Using it to promote bookkeeping, payroll, financial planning or other non-preparation services can require a properly executed taxpayer consent.

The permitted solicitation list is limited to certain fields, such as names, contact information, entity classification and tax form number. Don’t import prior refund amounts, income, deductions or other return details into a marketing audience.

Here’s the practical boundary. You may have a list of past clients with names and contact information that you originally collected during tax preparation. The limited solicitation exception is designed for tax preparation and qualifying educational communication, not for sending every offer your business now sells. A contact list pulled from another, independently obtained marketing source may have different rules, so keep its origin straight.

If you want to offer unrelated services using protected tax return information, use the appropriate separate, informed Section 7216 consent. That consent has specific content and timing requirements. Don’t treat a general website marketing checkbox as automatically satisfying the tax-return-information rules.

Keep the message simple

You don’t need a dramatic “We miss you” campaign. Try something like:

“Hi! We’re getting ready for the upcoming filing season and wanted to let you know our tax preparation calendar will be opening soon. If you’d like to work with us again, here’s how to get started. We’d be happy to help.”

Make the path back easy: one booking link, one intake link and a clear way to ask a question.

For promotional emails, follow CAN-SPAM requirements, including accurate sender information, a mailing address and a working unsubscribe method. Marketing texts have separate consent requirements; don’t assume permission to email means permission to text.

A short email can be enough, especially if it answers the question a former client has: “What do I do if I want you to prepare my return this year?” Tell them when intake opens and link directly to the next step. If you have a portal, explain whether they need to reactivate an account or complete a fresh organizer. The fewer choices, the better.

Send a helpful follow-up to people who haven’t responded, not the same sales message with a louder subject line. A reminder about tax documents or a filing-season deadline gives the message a reason to exist. Stop when someone opts out, and keep proper records of promotional communications.

Segment carefully, not creepily

It’s fine to tailor an outreach campaign within the rules. But avoid messages that reveal details from a former client’s return. “We noticed your refund was smaller last year” is not the kind of personalization you want.

Keep tax-preparation outreach focused on the service, what the client should do next and any broadly relevant filing-season information.

And respect opt-outs. If someone says they don’t want to hear from you, remove them from future solicitations.

Segments don’t need to be complicated. You might separate people who skipped one filing season from those who haven’t returned in several years. Business filers may need a different reminder about document collection than wage-only filers. Stay within the fields and uses the rules permit; do not create segments based on a person’s refund, deductions or other confidential return details.

And be careful with text messages. A prior tax appointment isn’t a universal permission slip for marketing texts. Confirm that the appropriate consent exists before loading a former-client list into an automated texting tool.

Measure return appointments, not vanity metrics

A successful reactivation campaign isn’t the one with the prettiest email report. It’s the one that brings qualified clients back through a process your team can handle.

Track how many former clients book, how many complete intake and what work actually comes through the door. Then improve the timing and message next season.

For a quick reality check, imagine reaching 200 former clients and getting 20 inquiries. If only five people complete the organizer and two actually file, the campaign has an intake problem—not necessarily a subject-line problem. Track the path from response to booked appointment to completed return. That tells you where to improve next season.

The takeaway: Reach out warmly, make rebooking easy and respect the privacy rules for taxpayer information. Our customizable Client Organizer Template gives returning clients one organized place to update their information before preparation begins.

Official source: IRS — Section 7216 Information Center.

For general education for tax professionals; reviewed October 23, 2026. Confirm current forms and guidance before relying on tax-law details.