Short answer. For tax year 2026 it is, unless you are exempt. Section G was optional for tax year 2025 and becomes mandatory for non-exempt filers the year after. Two groups stay exempt: Qualified Small Businesses that elect the Section 41(h) payroll-tax offset, and filers whose original return shows total QREs of $1.5 million or less and average annual gross receipts of $50 million or less over the prior three years. A company past both carve-outs, which is most teams at the Scale tier, has to complete Section G.
Key facts
| When it starts | Optional for tax year 2025; mandatory for non-exempt filers from tax year 2026 |
|---|---|
| Exemption 1 | Qualified Small Businesses electing the Section 41(h) payroll-tax offset |
| Exemption 2 | Original-return filers with QREs of $1.5M or less and average gross receipts of $50M or less (prior 3 years) |
| Who it binds | Filers past both carve-outs, which is most teams at the Scale tier (26 to 60 engineers) |
| What it asks for | Nine fields per business component, including the information sought to be discovered |
| Authority | IRS Instructions for Form 6765 (rev. December 2025); 26 U.S.C. Section 41(h) |
Optional in 2025, mandatory in 2026
The IRS phased Section G in across two filing seasons, and the second one is the deadline.
Section G is the schedule on the redesigned Form 6765 that breaks your research credit down by business component. For tax year 2025 returns it was optional, a voluntary trial run the IRS offered while companies adjusted. For tax year 2026, filed in processing year 2027, it becomes mandatory for every filer who does not land inside one of two exemptions.
The phase-in is the signal worth reading. Tax year 2026 is the first year a non-exempt company must hand the IRS a per-component account of its credit, and the work that account describes is happening now, across calendar 2026.
Who is exempt
The December 2025 instructions name two carve-outs, and there is no third.
- Qualified Small Businesses electing the payroll-tax offset. A QSB (broadly, a company under $5 million in current-year gross receipts with no gross receipts more than five years earlier) that elects the Section 41(h) offset against employer payroll tax is exempt from Section G. This is the common case for early-stage teams, and it covers the Indie tier and much of the Standard tier.
- Small-dollar filers on an original return. A filer whose originally filed return reports total QREs of $1.5 million or less (measured across the controlled group) and average annual gross receipts of $50 million or less over the prior three years is exempt. The limits are strict: it has to be an original return rather than an amended one, and crossing either threshold ends the exemption.
- If neither line describes you, Section G is mandatory starting tax year 2026.
Why it binds companies at the Scale tier
Both carve-outs are sized for small filers, and a 26-to-60-engineer team has usually outgrown them.
Run a Scale-tier company through the two exemptions. It has typically passed the QSB window, on revenue or on age or both, so the payroll-offset route is closed. And a team of 26 to 60 engineers has qualified research expenses well above $1.5 million, so the small-dollar route is closed too. What is left is the mandate.
This is the honest center of the case for documenting now. A contingency provider can offer to chase the credit later, but no provider can make Section G optional for a filer the rules cover. If you are non-exempt, the per-component report is a filing requirement no matter how the credit math lands. Indie-tier QSBs stay exempt, and we say so plainly rather than sell urgency that does not apply to them.
2026 is the documentation year
Section G asks for things that cannot be reconstructed convincingly after the fact.
Each business component on Section G carries nine fields: its name, type, and description, the information the team set out to discover, and five QRE figures. The one that resists invention is information sought to be discovered, the technical uncertainty you were resolving. Recorded as the work happens it reads as evidence; written in 2027 about work done in 2026 it reads as reconstruction, and an examiner knows the difference.
That is what makes 2026 the documentation year. The first mandatory Section G covers tax year 2026, and the commits that prove it are landing right now. R&D Binder assembles the per-component record from your GitHub history and payroll register as the year runs, so your CPA transcribes Section G instead of rebuilding it from memory. We document; your CPA files. See the nine fields, one at a time, or read how this works for CPA firms.
Keep going
The field-level mechanics, the tier this binds, and the people who file:
Sources
Every claim on this page traces to a primary authority. Each source below is independent and verifiable.
- IRS, Instructions for Form 6765 - Internal Revenue Service
- 26 U.S.C. § 41 (credit for increasing research activities) - Cornell Law School, Legal Information Institute
- IRS, About Form 6765 - Internal Revenue Service
- Treas. Reg. § 1.41-4 (recordkeeping and substantiation of qualified research) - Cornell Law School, Legal Information Institute
Get documentation built to survive an exam
If Section G is mandatory for you, the per-component record is easier to build as 2026 happens than to reconstruct in 2027. R&D Binder produces it from your commit history and payroll register; your CPA files the return. We never prepare or sign one.