Impact on Postmarking Timing: The rule clarifies that the date displayed on a machine-applied postmark represents the "date of the first automated processing operation" performed at a processing facility, rather than the date the mail was dropped off.
- Potential Delays: Because most postmarks are applied at processing facilities, the date inscribed may be later than the date the mail piece was first accepted by the USPS. This discrepancy is expected to become more common due to the implementation of the "Regional Transportation Optimization" (RTO) initiative and the adoption of "leg-based" service standards.
- Operational Reality: The rule codifies the operational reality that postmarking operations often cross calendar days or occur after transportation from a retail unit, meaning the postmark date is not a "perfectly reliable indicator" of the date of mailing.
Ensuring a Postmark on the Date of Delivery: To assure a postmark is applied on the same day a document is delivered to the USPS, individuals must utilize specific retail services. The final rule outlines the following methods:
- Request a Manual Postmark: Customers may present a mail piece at a retail counter and request a "manual (local) postmark". This postmark is applied at the time of acceptance, so the date aligns with the date the USPS took possession.
- Postage Validation Imprint (PVI): When a customer pays for postage at a retail counter, the PVI label applied by the employee also indicates the date of acceptance.
- Certificates of Mailing: Customers may purchase a Certificate of Mailing, or use Registered or Certified Mail, to obtain a receipt that serves as evidence of the date the item was presented for mailing
This change in USPS processes will have a potentially significant impact on tax filings. IRC §7502 specifically relies upon the postmark date applied to an envelope to determine timely filing if the document is not physically delivered to the IRS office by the due date for such document.