Can I file Form 2290 without an EIN?
No. The IRS requires every Form 2290 to be filed under an EIN (Employer Identification Number). SSN-based filings are not accepted, even for sole proprietors. EINs are free from the IRS and issued instantly online - but the IRS says a new EIN takes about four weeks to establish in its systems before a Form 2290 will be accepted, so plan ahead.
Form 2290 is filed under an EIN, even for owner-operators with a single truck. The IRS made EINs mandatory for HVUT in 2010 to prevent SSN-based identity exposure on a public tax form. There is no SSN-based filing path.
If you do not yet have an EIN, get one free from the IRS at irs.gov/businesses/small-businesses-self-employed/apply-for-an-employer-identification-number-ein-online. The application takes about 10 minutes and the EIN is issued instantly.
There is a waiting period of about four weeks after EIN issuance before Form 2290 will be accepted - the IRS says it takes about four weeks to establish a new EIN in its systems. If you try to file Form 2290 before the EIN is established, the IRS rejects with Code R0000-901 (EIN not on file).
Plan ahead: if you are about to put a new truck into service in July, apply for the EIN by early July at the latest so the August 31 Form 2290 deadline is not blocked. For mid-year first-use vehicles, the rule is the same - apply at least four weeks before the proration deadline.