Do 1099s Have to Be Filed Electronically? Threshold and Waivers

Do 1099s have to be filed electronically? Yes, if you’re submitting 10 or more information returns in a calendar year, counted across all form types combined. Below that threshold, paper is still allowed, though the IRS’s free online portal makes voluntary e-filing straightforward.¹

How the 10-Return Threshold Works

Federal law sets the mandatory e-filing trigger at 10 returns for any calendar year after 2021.² The old rule was 250 returns per form type, which kept most small businesses on paper. Two things changed: the number dropped to 10, and the count is now aggregated across form types rather than tallied separately.

What that means in practice: a landscaping company issuing six 1099-NECs to subcontractors and four W-2s to employees has filed 10 information returns total. All 10 must go in electronically. If the same company issued three 1099-NECs and four W-2s, that’s seven returns, and paper filing is still permitted. The line is clean. Ten or more, electronic. Fewer than 10, your choice.

Which Forms Count

Nearly every information return the IRS accepts feeds into the aggregated count. For most small businesses, the common ones are Form 1099-NEC (payments to independent contractors) and Form 1099-MISC (rent, prizes, and other miscellaneous income). The total also includes Forms 1099-INT, 1099-DIV, 1099-K, 1099-R, the entire 1098 series, the 5498 series, and Forms W-2 filed with the Social Security Administration.³

Beginning with tax year 2025 (filed in 2026), Form 1099-DA joins the list. It covers digital asset transactions reported by brokers, and for sales on or after January 1, 2026, brokers must also report cost basis for covered securities.⁴

Corrected returns don’t add a separate tally to the threshold. However, if your originals were required to be e-filed, any corrections must be e-filed too. You cannot fix a mistake by mailing a paper corrected form when the originals went in electronically.⁵

What Happens If You File Paper When You Should Have E-Filed

Filing on paper when you were required to e-file is treated the same as filing an incorrect return. The IRS assesses penalties per return, on a sliding scale that depends on how quickly you fix the problem. For returns due in 2026:

Corrected within 30 days of the due date: $60 per return
Corrected after 30 days but by August 1: $130 per return
Not corrected by August 1 or not filed at all: $340 per return
Intentional disregard: $680 per return or more, with no annual cap⁶

A parallel set of penalties under IRC 6722 applies when you fail to furnish correct statements to recipients — the copies your contractors and payees receive. The per-return amounts mirror the filing penalties, so a business that misses both the IRS filing and the recipient copies can face double penalties on the same returns.⁷

How to E-File 1099s

The IRS’s primary platform is the Information Returns Intake System, or IRIS. It’s free, web-based, and works for filers of any size. Through the IRIS Taxpayer Portal you can key in up to 100 returns at a time or upload them using a downloadable CSV template.¹

The older Filing Information Returns Electronically (FIRE) system still works for the current filing season, but the IRS has announced it will be retired after filing season 2027 (covering tax year 2026 returns). After that, IRIS will be the only intake system for information returns.⁸

Get a Transmitter Control Code First

Before you can submit anything through IRIS, you need a Transmitter Control Code (TCC), a unique identifier that ties your electronic submissions to your business. Apply online through the IRS’s IRIS Application for TCC, and do it well before your deadline. Processing isn’t instant, and a delay won’t excuse a late filing.⁹ FIRE uses a separate TCC obtained through a different application.¹⁰

Verify Your Identity Through ID.me

Accessing IRIS requires identity verification through ID.me. You’ll need a government-issued photo ID and a device that can take a selfie. Existing ID.me credentials from other government use will work.¹¹

Verify Payee TINs Before You File

Incorrect Taxpayer Identification Numbers are one of the most common reasons for rejected filings and penalty notices. The IRS runs a free TIN Matching Program that verifies name-and-TIN combinations against IRS records. The interactive version handles up to 25 lookups with instant results; the bulk version processes up to 100,000 within 24 hours.¹² If a payee refuses to provide a valid TIN, you’re generally required to withhold 24% of their payments as backup withholding.¹³

1099 Filing Deadlines

Deadlines depend on the form and on whether you’re sending copies to recipients or to the IRS:

Form 1099-NEC: Recipient copies and IRS filing are both due January 31. No split deadline, no extra time for electronic filers.
Form 1099-MISC: Recipient copies are due January 31. IRS filing is due February 28 on paper or March 31 if electronic.
Forms 1099-B, 1099-DA, and 1099-S: Recipient copies are due February 15. IRS filing follows the same February 28 (paper) or March 31 (electronic) schedule.¹⁴

When a deadline falls on a weekend or legal holiday, it shifts to the next business day. The extra month between paper and electronic deadlines for the 1099-MISC and similar forms is a real benefit of e-filing, but it doesn’t apply to the 1099-NEC. That January 31 date is firm regardless of filing method.

Extensions and Hardship Waivers

If you can’t meet a filing deadline, Form 8809 gets you an automatic 30-day extension when submitted by the original due date. It can be filed electronically through IRIS or on paper. No signature or explanation is required for the initial 30-day extension, but the request must arrive by the deadline.⁵ An extension to file with the IRS does not extend your deadline to furnish copies to recipients.

If you genuinely cannot comply with the e-filing requirement because of financial hardship or a technological barrier, you can request a waiver using Form 8508, submitted at least 45 days before the returns are due.¹⁵ The IRS grants these sparingly. Finding e-filing inconvenient is not enough.

Organizations with religious objections to using technology are automatically exempt. No formal waiver is necessary, though the IRS encourages filing Form 8508 with Block 6 completed so the exemption is on record. Once filed, the notification doesn’t need to be repeated in future years.

State Filing Is a Separate Question

Federal e-filing does not automatically satisfy every state’s reporting requirements. IRIS supports the Combined Federal/State Filing Program, which forwards return data to participating state tax agencies, but not every state participates, and some states require additional forms or direct filings even for participants.¹⁶ Check with your state’s department of revenue before filing season so you know whether your federal submission covers state obligations or whether you need to file separately.

1
Internal Revenue Service. E-file Information Returns With IRIS
2
Office of the Law Revision Counsel. 26 USC 6011 – General Requirement of Return, Statement, or List
3
Internal Revenue Service. E-file Information Returns
4
Internal Revenue Service. Instructions for Form 1099-DA (2025)
5
Internal Revenue Service. Publication 1099 (2026), General Instructions for Certain Information Returns
6
Internal Revenue Service. 20.1.7 Information Return Penalties
7
Internal Revenue Service. Revenue Procedure 2024-40
8
Internal Revenue Service. Filing Information Returns Electronically (FIRE)
9
Internal Revenue Service. IRIS Application for TCC
10
Internal Revenue Service. About Information Returns (IR) Application for Transmitter Control Code (TCC)
11
Internal Revenue Service. New Identity Verification Process to Access Certain IRS Online Tools and Services
12
Internal Revenue Service. Taxpayer Identification Number (TIN) Matching Tools
13
Internal Revenue Service. Publication 15 (2026), (Circular E), Employer’s Tax Guide
14
Internal Revenue Service. Instructions for Forms 1099-MISC and 1099-NEC (04/2025)
15
Internal Revenue Service. Form 8508 (Rev. 11-2023) Application for a Waiver From Electronic Filing of Information Returns
16
Internal Revenue Service. Combined Federal/State Filing (CFSF) Program State Coordinator Information FAQs