ITIN Without a Passport: What Alternative Documents the IRS Accepts

Why Would Someone Apply for an ITIN Without a Passport?

Most ITIN applicants use a current passport because it is the only standalone document the IRS accepts for both identity and foreign status. The minority who apply without one typically fall into 4 buckets: the passport is expired and renewal is slow, the country of citizenship does not issue passports easily, the applicant is a dependent child without a passport, or the original passport is unavailable because it is held for visa processing in another country.

The IRS designed the alternative-document list for exactly these cases. For the full document checklist see the ITIN documents required guide.

What Are the 13 Documents the IRS Accepts on Form W-7?

The IRS publishes a list of 13 acceptable documents on the Form W-7 instructions. Each document proves identity, foreign status, or both. Only the passport proves both on its own — every other document must be combined.

How Do You Combine Documents to Replace a Passport?

The IRS requires at least 1 foreign-status document AND at least 1 identity document. Some documents serve both roles. The strongest non-passport combinations:

1. National ID card alone— if it includes photo, full legal name, current address, date of birth, and expiration. Many Mexican, Indian, Brazilian, and EU national IDs meet this bar.
2. Foreign birth certificate + foreign driver license — works for adult applicants whose birth certificate is certified by the issuing civil registry. Birth certificates count for identity only for dependents under 18, so adults must add the driver license.
3. USCIS photo ID + foreign voter registration card — common for applicants already inside the US with a USCIS Employment Authorization Document.
4. Visa + US or foreign driver license— visa proves foreign status and the license proves identity.
5. Foreign military ID card alone— satisfies both requirements when current.

How Does the IRS Verify Non-Passport Documents?

The IRS uses 3 verification paths for ITIN documents:

• Mailed originals. The applicant ships physical originals to the IRS ITIN Operation in Austin, TX. The IRS holds the document for 60 days, then mails it back. Risk: lost mail.
• Issuer-certified copies. The applicant requests a certified copy directly from the issuing agency (passport office, civil registry, USCIS). Notarization does NOT count.
• Certifying Acceptance Agent verification. A CAA physically reviews the original on-site, signs Form W-7 (COA) certifying the document, and the applicant keeps the original. This is the lowest-risk path.

What Mistakes Cause Non-Passport ITIN Applications to Fail?

• Submitting only one document when the chosen document does not satisfy both foreign-status AND identity requirements. The IRS auto-rejects.
• Notarized photocopies. Rejected since 2019.
• Expired documents. Even by one day. The IRS checks expiration on every document.
• School or medical records for adult applicants. These are valid only for dependents under 18 (school) or under 6 (medical).
• Name mismatch between Form W-7 and the supporting documents. Spelling, accents, and order all matter.

When Should You Renew the Passport Instead of Using Alternatives?

Renew the passport when (1) the alternative-document combination requires mailing originals you cannot afford to lose, (2) the applicant is in the US and passport renewal at the embassy is faster than gathering certified copies, or (3) the IRS rejected a prior non-passport application. A renewed passport processed through a Certifying Acceptance Agent returns the ITIN in 7 to 11 weeks with zero document risk.

For details on the no-passport path see the dedicated ITIN without passport guide.