The Pentera Blog
It's the End of the Mailbox Rule as We Know It
Back in 1987, Rock and Roll Hall of Fame inductee R.E.M. released a song titled “It’s the End of the World as We Know It (and I Feel Fine).” (Hopefully, this will provide you with an ear worm for the rest of the day.)
On November 24, 2025, the United States Postal Service (USPS) adopted a final rule in the Domestic Mail Manual titled "Postmarks and Postal Possession” to be effective on December 24, 2025. This rule clarifies that machine postmarks are applied at regional processing centers, not the local drop-off point.
As a result, the date of the machine postmark can be several days later than when a piece of mail was handed over to the USPS. This has the potential of impacting how your donors should deliver their year-end gifts to make sure that they qualify for an income-tax deduction this year.
Treasury Regulation §1.170A-1(b) defines when a charitable gift is deemed to have been delivered to determine the year of deduction and the gift’s valuation. IRS Publication 526 provides examples of how these rules work, quoted below:
- Time of making contribution. Usually, you make a contribution at the time of its unconditional delivery.
- Checks. A check you mail to a charity is considered delivered on the date you mail it.
- Stock certificate. A properly endorsed stock certificate is considered delivered on the date of mailing or other delivery to the charity or to the charity's agent. However, if you give a stock certificate to your agent or to the issuing corporation for transfer to the name of the charity, your contribution is not delivered until the date the stock is transferred on the books of the corporation
Traditionally, the postmark date has been used to prove when a gift was mailed. The new USPS rule states that the machine-applied postmark from the regional processing center represents the “date of the first automated processing operation,” and that the postmark date is not a “perfectly reliable indicator” of the date of mailing.
Obviously, the postmark can no longer be used to confirm when a gift was mailed to determine the date of a charitable contribution.
Here is an example for what donors should do going forward: Mary wishes to make a gift that she can deduct on her 2025 taxes. She drops a check in the big blue mailbox at her local USPS on December 31. Her check is placed on a truck, routed to a USPS regional processing center, and a postmark is affixed on January 2, 2026. As she cannot prove that she mailed the check in 2025, her gift will be deemed to have been made in 2026 due to the postmark.
Does Mary have any options for proving that she actually mailed her check on December 31?
Yes, she does, but all of her options require her to go into a post office and hand her envelope to a USPS staff member. There are a few options she can use to prove the date she mailed her gift:
- Postage Validation Imprint (PVI): Mary can purchase postage at the counter. The PVI label created by the USPS staff member will state the date of mailing.
- Manual Postmark: Mary may also ask the USPS staff member at the counter to affix a “manual (local) postmark.” This postmark will confirm the date of mailing.
- Additional Purchases: Mary may purchase a Certificate of Mailing. She can also pay an additional amount to mail her gift via Registered or Certified Mail. All of these methods confirm the date of mailing.
To continue our example, suppose that Mary goes to her local post office and encounters a line of three dozen people. Rather than waiting in that line, she goes to the self-service kiosk to purchase postage. Even though she prints postage that shows a date, that date proves only when Mary purchased the stamp and is not proof of when she mailed her gift.
Can’t Mary just use FedEx or UPS? Unfortunately, the IRS is silent on using private delivery services for charitable gifts. Most commentators agree that a gift sent via a private delivery service is not unconditionally delivered until the charity actually receives it.
Mary’s safest choice (perhaps her only choice) to confirm the date she mailed her gift is to go to the USPS counter at her local post office, purchase her postage, and leave the envelope in the hands of a USPS staff member.
One final detail…Mary’s check must clear her bank within due course in order for it to be a 2025 gift. If her check bounces, her gift will not be a 2025 gift, even if she immediately puts funds in her account to cover it.
A QCD Cautionary Tale: Sam has a checkbook to make withdrawals and qualified charitable distributions (QCDs) from his IRA. Sam wishes to make a QCD in 2025 and mails a check from his IRA on December 30 using a PVI that he purchased at the USPS counter. He accomplished his goal, right?
Unfortunately, he did not. QCDs are deemed to have been made when the funds are actually withdrawn from the IRA. Even if the charity receives Sam’s IRA check on December 31, it would be virtually impossible for Sam’s IRA administrator to move the funds that quickly. QCDs should be made by early to mid-December in order for the funds to be transferred before the 31st.
Given the late date of this new rule, it is practically a given that your donors will not be aware of the new mailbox rule. Nor will your gift processing staff.
At a minimum, you should make sure that your gift processing team is informed of the new rule. If you have the ability to send out a mass electronic communication, you might consider sending an update to donors who traditionally make year-end gifts and even to a broader audience as a public service announcement.
Many thanks to my colleague and friend David Cahoone for alerting me to this new USPS rule.
