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Redesigned Withholding Compliance Lock-In Letters 2800C and 2808C

**Updated on September 24, 2020: SAP Note 2967813 released for all customers**

SAP has released SAP Note 2967813. This SAP Note delivers a correction for Redesigned Lock-in letters in scenarios with Additional Withholding.

**Updated on August 21, 2020: SAP Note 2951750 released for all customers**

On March 4th, 2020, the IRS issued the Special edition of e-News for Payroll Professionals – Redesigned Withholding Compliance Lock-In Letters 2800C and 2808C coming soon (

The IRS stated that “The Tax Cuts and Job Act of 2017 (TCJA) changed withholding calculations by eliminating allowances, and in response, the IRS redesigned Form W-4, Employee’s Withholding Certificate. The Service is also redesigning the Withholding Compliance Lock-in Letters to reflect these changes.”.

After receiving a lock-in letter in the new format, customers have up to 60 days to start withholding based on that lock-in information.


To enable you to comply with this legal change, SAP has released SAP Note 2951750 – [US] New 2020 Lock-in letters. This SAP Note 2951750 delivers the following changes:

  • Payroll changes in the USTAX payroll function
  • New fields in infotype IRS Limits USA (0161), as required by the new lock-in letter format. For a preview of these changes, see the screenshot below:


SAP Note 2958696 delivers the same changes for HR Renewal.

I hope you find this information helpful!

Best regards,


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  • Hi,

    I was testing using a withholding override using an additional withholding amount on the IT0161. The system seems to ignore the additional amount in tax calculation? Is this expected?

    • Hi Syam Ponnada,

      They are the same. In other words: the field “Total credits for dependents” in the system corresponds to the information you find on Form 2800C, “Annual reductions from withholding”.

  • Hello -

    Has anyone had this error?  Did I miss a config setting somewhere?

    Data record 000000000161FED    9999123120181216000 is not between 04/08/2018 and 11/16/2019
    Data record 000000000161FED    9999123120181216000 is not between 11/17/2019 and 12/31/9999

    I have an employee whose last IT0210 FED record is from 11/19/2017  to 12/31/9999 so this does not fall in the 2020 changes.  This employee also had an IT0161 FED record dated 12/26/2018 to 12/31/9999.  We have received a new 2020 lock in letter and need to create the IT0161 record starting 12/27/2020, but we are getting the above errors.





    • Hello Alicia,

      This doesn't seem related to any config related to the new fields.

      If you don't figure it out, create an OSS Ticket so our colleagues can have a look into your system.

      Best regards,

      • Marcelo -

        It's as if it's a time constraint issue, but there shouldn't be a time constraint on this IT.

        Message No. PBAS_SERVICE038

        The system identifies the data record as inconsistent

        • Customer-specific settings for grouping infotypes have been changed without the database being adjusted accordingly.
        • A customer program was used to add data to the database, without reference to the grouping values.
        • The infotype is not supposed to be grouped, but the grouping mechanism was activated inadvertently.

        I have checked table V_T582A and there are no constraints to create this error.  Where else could this be coming from?

        I want to make sure I've checked all areas before I log a message with SAP.

        • Hi Alicia,

          I see, it makes sense to check things on your end before logging a message. So, some points to help you out on this search:

          I agree that this seems as a time constraint issue. However, that's also strange because as you've pointed out - this IT should not have. Furthermore, nothing in this sense was changed with the new Lock-in format.

          Another thing that puzzles me is why these dates? What has happened to this employee that the system doesn't allow a record to cross from 11/16/2019 to 11/17/2019?

          Do you have CE active in your system? And have this employee had a Tax Company change in this day? These are some things that I can imagine to affect this scenario, but they are more related to the Core (international) infotype framework and probably should have happened before as well.

          Best regards,

          • Marcelo –

            The employee did change company codes on 11/17/19, but why should that impact the IT0161 setting?  We don’t require a change to IT0210 when an employee changes company codes.  We have never hit this issue until the new changes went in, but I would have to review all of our old pre 2020 setups to see if anyone ever changed companies.  I’m sure they have because that’s a regular occurrence here.

            It appears we have more than this one issue as of today.  We have another employee that the error is on a personnel area they had at hire date 20 years ago.  We are keying an IT0161 record for the very first time on this employee.  Looks like I'll be logging a message this afternoon.

          • Marcelo -

            I logged the following message with SAP:

            836604/2020 IT0161 errors when creating new records

            This is a high issue with us as employers have timeline requirements on getting the new lock-in letters set up on employees and to withhold the correct taxes.  We are unable to create any new 2020 or 2021 records due to the multiple errors we are receiving.


  • Hello Randall Allred

    I'm just curious if you've had any issues creating new 2020 or 2021 IT0161 records for employees?

    Do you change the IT0161 records when an employee changes company codes (if you have multiple companies)?

    Does anyone else have this situation?



  • Hello community,

    It seems that the calculations are not correct when the lock-in letter is in a new format (i.e. BEGDA >= 01/01/2021) and the employee is on the old format of the W-4. We are thinking about asking our employees who have received IRS lock-in letter to create a new W-4 form. Has anyone faced this issue?



    • Hello Thomas,

      Which issues are you facing? Is the new Lock-in not being used for calculation?

      Please, bear in mind that the system will always perform the Income Tax Withholding calculation using both forms - the W-4 information and the lock-in information. And then it will pick the one that results in a higher tax amount.

      Best regards,