Plan Your Postmark: Operational Changes at USPS Can Affect Gift Dates
In 2025 the US Post Office made a quiet shift in its operations that resulted in some gifts handed to the US Post Office on December 30th and 31st being postmarked in January. Donors and charities should be aware of this change, as the mailbox rule to establish a gift date for a mailed check relates to when the postmark is applied not when the US Post Office came in possession of the mail.
Mail deposited in mailboxes, retail locations, and US Post Offices is sent to central processing facilities for sorting. Even though the US Postal Service (USPS) has possession of the mail, the postmark is not usually applied until the mail reaches a processing facility. In 2025 the US Post Office made changes to its transportation operations which no longer guarantee that mail deposited in a mailbox or handed to a postal worker at a retail post office will arrive at a processing facility on the same day. This means mail that is simply dropped off in a mailbox or US Post Office may not be postmarked for a day or two until it reaches the processing facility. As a result, the date on the postmark applied at a processing facility will not necessarily match the date on which a letter was collected by a letter carrier, handed over the counter to a post office employee, or dropped in a mailbox.
The solution for donors making year-end gifts by mailing a check is to request that their envelope be postmarked in front of them at their local US Post Office. A manual postmark continues to be available at local post offices, but it will not be applied automatically as it must be specifically requested.
The mailbox rule for gifts of cash or checks provides that the date of the gift is the postmark on the envelope. Treas. Reg. §1.170A-1. This is particularly important for gifts at year end which need to be postmarked by December 31 to be considered a gift in the current year. Please note the date of the gift for a qualified charitable distribution (QCD) from an individual retirement account (IRA) written by the IRA manager is the date on the check from the IRA not the postmark.
This operational change also has implications for your donors’ tax filings, the filing of Form 5227 for charitable trusts, and the mailing of paper 1099-Rs. The Internal Revenue Service (IRS) uses the USPS postmark to determine the timely filing of tax returns and information returns. Waiting in line at the US Post Office to receive the postmark in time may continue to be part of the tax filing routine for some. The IRS does accept certain private delivery services to meet the timely mailing requirements as well:
www.irs.gov/filing/private-delivery-services-pds
Don’t forget the deadline to file paper Forms 1099-Rs with the IRS is March 2, 2026. An organization with nine or fewer Forms 1099-R must submit the Form 1096 and the Forms 1099-R (Copy A) to the IRS postmarked on or before March 2, 2026. The deadline to file Forms 1099-R electronically to the IRS is March 31, 2026. With tax returns coming due soon, be sure to make time to head to a US Post Office for that timely postmark.