{
  "id": "BRD-027",
  "slug": "brd-027",
  "title": "EIN must be old enough to have propagated to IRS records",
  "statement": "A newly issued EIN is not yet present in the records vetting providers query; registration fails until it propagates.",
  "rationale": "A newly issued EIN is not yet visible to the databases vetting providers query, so verification fails against a record that does not exist yet. No form correction fixes this — the only remedy is time, which is worth knowing before paying a non-refundable vetting fee.",
  "layer": "BRAND",
  "layerSlug": "brand",
  "object": "brand.ein",
  "severity": "HIGH",
  "detectability": [
    "EXTERNAL_DATA",
    "HUMAN"
  ],
  "failureClass": "TERMINAL_EXTERNAL",
  "authorities": [
    "AWS",
    "Twilio",
    "Bandwidth"
  ],
  "applicability": {
    "excludeEntityTypes": [
      "SOLE_PROPRIETOR"
    ]
  },
  "applicabilityText": "Applies when the brand is NOT a sole proprietor.",
  "universal": false,
  "remediation": "If your EIN was issued in the last 90 days, wait before submitting. No form correction fixes this — vetting queries a record that does not exist yet.",
  "notes": "Providers publish different windows (AWS 30 days, Twilio 30-90, Bandwidth 90). Strictest kept per the strict-superset model.",
  "phase": "approval",
  "automated": false,
  "attestation": {
    "question": "Was this EIN issued more than 90 days ago?",
    "howToCheck": [
      "Find the issue date printed on the CP-575 confirmation letter.",
      "Count the days to today. Under 90, wait rather than submit — providers publish windows from 30 to 90 days and the longest is the one worth planning against."
    ],
    "failureLooksLike": "An EIN issued three weeks ago matches nothing, and the rejection says the business could not be found rather than that the EIN is too new — so a perfectly correct name and address get edited over and over."
  },
  "url": "https://ekas.io/rules/10dlc/brand/brd-027/",
  "markdown": "https://ekas.io/rules/10dlc/brand/brd-027.md",
  "registry": "https://ekas.io/rules/10dlc/",
  "updated": "2026-07-25",
  "licence": "CC BY 4.0 — https://creativecommons.org/licenses/by/4.0/"
}