Capitol Insights: Breaking down the new WOTC expansion bill

Dec 1, 2025
Capitol Insights: Breaking down the new WOTC expansion bill

Capitol Insights provides weekly updates on federal activity that may affect employer tax credits, workforce planning, and hiring incentives. Each edition focuses on developments that matter for organizational strategy and long-term decision making.

Latest update

Our latest Insight focused on the introduction of the Improve and Enhance the Work Opportunity Credit Act, a proposal that would update WOTC eligibility rules and expand support for several target groups. It also highlighted the growing bipartisan interest surrounding the extension and renewal of the Work Opportunity Tax Credit. Read Week 7 here .


At a glance:

  • Bipartisan bill proposes a five-year Work Opportunity Tax Credit extension

  • Wage calculations would shift to a two-tier structure

  • WOTC qualified wages would be indexed to inflation

  • The SNAP age limit would be removed

  • A new target group would be created for military spouses

  • Most updates would apply to individuals hired after December 31, 2025


Understanding the proposal

Lawmakers introduced the Improve and Enhance the Work Opportunity Credit Act to extend the Work Opportunity Tax Credit through 2030 and update several parts of how the credit is calculated. The Senate version is S. 3265 and the House version is H.R. 6321. Senate cosponsors include Roger Marshall, Peter Welch, and Catherine Cortez Masto on the Finance Committee, and John Boozman, Tim Kaine, Jerry Moran, and Jim Justice outside the committee. The full House cosponsor list has not yet been published.

Although the bill is still early in the legislative process, the proposed updates are important for employers preparing workforce and budget plans for 2025 and future years.

Key differences

Below is a summary of how the proposal compares to current WOTC rules.

Topic Current WOTC Proposed Changes

Program sunset

Scheduled to end Dec 31, 2025

Extends for five years through Dec 31, 2030

Wage base

Up to 40% of the first $6,000 in qualified first-year wages

50% of the first $6,000 in qualified first-year wages, plus 50% of an additional $6,000 for employees who complete at least 400 hours. Wage limits for veterans, summer youth employees, and long-term family assistance recipients would also be updated

Inflation indexing

Not indexed

Indexed to 2024 inflation

SNAP age limit

Age cap applies

Age limit removed

Military spouses

Not a stand-alone category

New WOTC target group

Outreach initiative

No formal initiative

Federal agencies are authorized to promote WOTC in key industries

Effective dates

Current rules in place

Most updates apply to hires after Dec 31, 2025

 

The table provides employers with a simple view of how eligibility, credit value, and administrative considerations could shift if the bill moves forward.

What this means for employers

If enacted, these changes would affect how organizations evaluate and plan for WOTC-related savings.

For employers already using the Work Opportunity Tax Credit, the proposed wage base update may increase the potential credit for eligible hires, especially for roles with higher wage levels or longer training periods. Indexing wages to inflation would help the credit keep pace with rising compensation, reducing the gap between actual labor costs and the credit’s capped amount.

Removing the SNAP age limit and creating a stand-alone category for military spouses would broaden WOTC eligibility in ways that may strengthen hiring pipelines. Many employers already engage these groups, and expanded eligibility could make WOTC calculations more straightforward.

For employers not currently leveraging the WOTC tax credit, the proposed updates could make participation more attractive. A longer extension through 2030 improves predictability, and the expanded categories may open new paths to eligibility. These conditions support stronger planning around tax credit forecasting and workforce investment.

A more strategic look at legislative activity

Rather than focusing narrowly on procedural steps, it is helpful to view this proposal through the lens of congressional timing and employer impact. WOTC has historically received bipartisan support, and the structure of this bill indicates an effort to stabilize the credit for several years. This aligns with broader federal discussions on workforce participation and hiring incentives.

While there is no formal movement scheduled yet, multi-year extensions often emerge within larger tax packages. The approach taken here suggests that lawmakers are positioning WOTC for long-term renewal once broader negotiations begin.

Why these updates matter

The proposed changes reinforce the role of the Work Opportunity Tax Credit in supporting employers that hire from underrepresented or overlooked populations. Updated wage thresholds reflect current labor costs and reduce the risk that wages outpace the credit’s value. Inflation indexing helps maintain consistency over time, and expanded eligibility rules may support industries experiencing shortages.
Together, these factors strengthen WOTC as a tool for workforce planning rather than a year-to-year incentive.

If you have questions about how the Improve and Enhance the Work Opportunity Credit Act may influence your hiring strategy, eligibility forecasting, or credit value, our WOTC specialists can help you review potential impacts and plan ahead.

 

Topic:

WOTC
As Vice President, Kitty is responsible for business development and strategy, partnering with employers to administer the Work Opportunity Tax Credit Program, and serving on the board of the National Employment Opportunity Network (NEON).