IRS lowers e-filing threshold to 10 information returns of any type

Eric Updated by Eric

It's official—the IRS now requires employers to electronically file the following forms if they have an aggregate of 10 or more of:

  • W-2
  • 1099 series
  • 1098 series
  • W-2G
  • 1042-S
  • 1094
  • 1095 series
  • 3921
  • 3922
  • 8027
This requirement applies to filings for Tax Year 2023 and beyond (i.e. forms that are filed starting in 2024).
Calculating the number of returns —(i) In general. For purposes of this section, a filer is required to file at least 10 returns if, during the calendar year that includes the first day of the plan year, the filer is required to file at least 10 returns of any type, including information returns (for example, Forms W-2 and Forms 1099), income tax returns, employment tax returns, and excise tax returns.

Affected employers should take steps now:

  1. Apply for a TCC code to e-file 1099's
CA E-filing is Mandatory if you E-filed your 1099's to the IRS (regardless of the # of 1099's)
  1. Register with BSO to e-file W2's
  • Request access to SSA Services Suite for Employer. After Registering, the BSO will mail a one-time activation code to your employer. When you receive the activation code, return to the BSO Welcome page, select Log In and provide your User ID and password. Select, Enter Your Activation Code and enter your activation code. You will then be able to use the service.
  • Register with the appropriates states to e-File your W-2's to the state
  1. Re-evaluate your need for paper forms
  2. Purchase or renew the W-2/1099 e-File Add-on and review the documentation.
The IRS recommends obtaining a Transmitter Control Code (TCC) by November 1st as the process may take 45 days.
Corrected returns must be filed in the same manner as the original: e-filed or paper filed.

About the new regulation

The Taxpayer First Act gave the IRS the authority to mandate that filers filing 10 or more of any type of information returns in aggregate do so electronically beginning with the 2022 tax year, but didn't exercise that authority until February 2023.

Furthermore, corrected returns must be filed in the same manner as the original: e-filed or paper filed.

The IRS recommends obtaining a TCC by November 1st as the process may take 45 days.

For further reading, see Electronic-Filing Requirements for Specified Returns and Other Documents, particularly:

The IRS has the authority to penalize any employer who does not file electronically if they meet the threshold.

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