IRS Liens and Levies: Is Enforcement Coming Back?

Key numbers

• 214,099lien notices filed in FY 2025, a third straight yearly riseIRS Data Book, Table 4-1
• 339,137levies on third parties in FY 2025, 90.6% below FY 2010IRS Data Book, Table 4-1
• 50seizures in FY 2025, the fewest of any year back to FY 1994IRS Data Book, Table 4-1 and all-years files
• 2,592revenue officers on the payroll at the end of FY 2025, down from 5,922 in FY 2010IRS Data Book, Table 6-3

Liens and levies, FY 2010 to FY 2025

Close-up: FY 2019 to FY 2025

What the data shows

• Enforcement fell steeply, though not every year. Lien notices dropped from 1,096,376 in FY 2010 to 157,323 in FY 2022, and levies from a high of 3,748,884 in FY 2011 to 273,286 in FY 2022 (IRS Data Book, Table 4-1). Along the way levies rose in FY 2014, FY 2018 and FY 2019, and lien notices in FY 2019 (Table 4-1).
• Both have risen each year since. Lien notices reached 214,099 in FY 2025 (+36.1% from FY 2022) and levies 339,137 (+24.1%, Table 4-1).
• The rise is small next to the old levels: FY 2025 lien notices were 80.5% below FY 2010 and levies 90.6% below (Table 4-1).
• Seizures of property fell to 50 in FY 2025 from 776 in FY 2011, despite small rises in FY 2016, FY 2021 and FY 2024 (Table 4-1). That is the fewest in any year of the Data Book’s all-years files, which start in FY 1994.
• The IRS had 2,592 revenue officers, its field collection employees, on the payroll at the end of FY 2025, down from 3,409 a year earlier and 5,922 at the end of FY 2010 (IRS Data Book, Table 6-3). The IRS says its agency-wide drop in employees in FY 2025 was mainly due to deferred resignation, early retirement and separation incentive programs (Table 6-3, note 3). Measured in full-time equivalents over the year, revenue officer staffing was 3,320 in FY 2025, up from 2,698 in FY 2023 (Table 6-3).

So, is enforcement coming back? Lien and levy counts have grown three years in a row, but they remain far below their 2010 to 2015 levels (IRS Data Book, Table 4-1). This page describes the trend only; it does not forecast what the IRS will do next.

The data, year by year

Swipe the table sideways to see every column.

Revenue officer counts: end of year = employees on the payroll at the end of the fiscal year; full-time equivalent = staff time used over the year. Download the table as a CSV: irs-liens-levies-seizures-fy2010-2025.csv (free to reuse under CC BY 4.0 with credit to Global Gate Tax Relief).

What this means if you owe the IRS

• These are national totals for each year, not a measure of any one person’s risk. A balance that sits unpaid can still lead to a lien or a levy at any point in the trend.
• A lien and a levy are different. A lien is the government’s legal claim on your property; a levy takes money or property. Our guide IRS tax lien vs levy explains both and the notices that come before them.
• Levy counts include requests from the IRS’s Automated Collection System as well as its field staff (IRS Data Book, Table 4-1, note 8), so fewer revenue officers does not mean no levies.
• You usually have appeal rights before a levy. The IRS Independent Office of Appeals received 24,191 Collection Due Process cases in FY 2025 (IRS Data Book, Table 4-3). If you have a final notice such as LT11 or CP504, read it the day it arrives.
• Seizures of property such as homes, cars or business assets are rare: 50 nationwide in FY 2025, against 339,137 levies on third parties such as banks and employers (IRS Data Book, Table 4-1). See our bank levy and tax lien pages.

Method and limits

Lien notices filed, levies on third parties and seizures come from IRS Data Book Table 4-1, “Delinquent Collection Activities”, and its earlier editions (Table 27, 25 and 16). For each fiscal year (October 1 to September 30) we used the latest edition that reports it. The IRS counts lien requests entered into its Automated Lien System, levies requested on third parties by its Automated Collection System and field collection, and seizures by field collection. Editions through FY 2012 call levies “served” rather than “requested”; the FY 2012 figure is the same under both labels.

Revenue officers come from the Data Book personnel table (Table 6-3; earlier Table 34, 32 and 30), which gives both the number of employees at the end of each year and full-time equivalents. From the FY 2021 edition on, the end-of-year count is employees in pay status at the end of September.

Cite this study

Global Gate Tax Relief, “IRS Liens and Levies, FY 2010-2025: Is Enforcement Coming Back?,” published November 13, 2026, https://globalgatetaxrelief.com/research/irs-liens-levies-trend/. Data: IRS Data Book, Tables 4-1 and 6-3.

Reporters and researchers may reuse the chart and the CSV with credit and a link to this page.