Review your farm entity structure before the 2026 FSA deadline and learn why updates may affect program payment eligibility.
Important deadline: September 15, 2026
FSA letters have been going out reminding agricultural producers to update their CCC-902 Farm Operating Plans by September 15, 2026.
Beginning with the 2026 crop year, for payment eligibility purposes, the Farm Service Agency (FSA) will treat applicable limited liability companies (LLCs), S corporations, and other similar entities as qualified pass-through entities (QPTs) if they are taxed as a partnership, joint operation, or similar entity.
Each member of a QPT who meets all payment eligibility criteria can help qualify the entity for expanded payment limitations.
Who should take action?
Farming operations organized as LLCs, S corporations, or limited partnerships that participate in FSA programs should review their entity tax structure and contact their local FSA office to update their Program Year 2026 Farm Operating Plans.
If you are unsure whether your operating entity qualifies as a pass-through entity, consult with your attorney, CPA, or tax advisor.
Key filing requirements
- To be considered a QPT for 2026, the entity must be designated as such with FSA by
September 15, 2026. - Farm Operating Plan changes for 2026 may be accepted after that date; however, entity tax structure changes made after September 15, 2026, will generally be effective for Program Year 2027.
- According to FSA guidance, supporting documentation is not required but may be submitted and retained in your file for future spot-check purposes.
- For QPTs, a new CCC-902 Farm Operating Plan must be filed for Program Year 2026, and all first-level members must sign the form.
- Entities that are not considered pass-through entities must still contact their FSA office and update their CCC-902 Farm Operating Plan.
Why this matters
In all cases, a new CCC-902 Farm Operating Plan for Program Year 2026 must be filed before an entity will be eligible for applicable FSA or Natural Resources Conservation Service programs and payments. If you have questions, contact your local FSA office.
This appears to be an important administrative step for agricultural operations to complete before harvest season. Make sure it is on your to-do list.
Practical steps for farm businesses
Farm operations should consider taking the following actions:
1. Review entity structure and tax classification
Confirm how each farming entity is taxed and whether it may qualify as a pass-through entity under current rules.
2. Coordinate with advisors
Consult with your CPA, tax advisor, or attorney so entity classifications and ownership structures are properly understood and documented.
3. Verify ownership information
Make sure ownership records are accurate and that information regarding active participation is readily available if requested.
4. Engage with your local FSA office early
Given the volume of updates expected nationwide, scheduling discussions and completing required paperwork in advance may help avoid delays.
How CLA can help
While these filing requirements may seem administrative in nature, they could have meaningful implications for payment eligibility and participation in certain USDA and conservation programs.
Farm entities that proactively review their structure and complete any required filings before applicable deadlines will be better positioned to avoid disruptions and enhance available program opportunities.
CLA can help you revisit your overall entity structure, evaluate potential tax considerations, and coordinate with your legal and FSA contacts so required updates are handled with the right context.
Our agribusiness, tax, and accounting professionals can also help identify related strategies tied to payments, compliance, and long-term business goals.