Filing Requirements Reminder for W-2s and 1099s

December 3, 2024

Last year, the IRS updated the filing requirements for the W-2s and 1099s. If you file an aggregate of 10 or more of these information forms, you are required to file them electronically. The IRS also recommends that less than 10 aggregate W-2s and 1099s be filed electronically. A penalty will be assessed if you file returns on paper that were required to be filed electronically. Also, if you need to file a correction and the original return was submitted electronically, you will be required to submit the correction electronically.

Registering for an account with the Social Security Administration for filing your W-2s

If you do not have an account with the Social Security Administration, it is highly recommended that you register now with the SSA now so that you are ready to file your W-2s in January 2025. The registration can be found here: Business Services Online (ssa.gov). We suggest that you start the process now to avoid any issues when it is time to file your W-2s. If you registered in a prior year, now is a good time to check to ensure that your information, including your password, is current. You must have a Social Security username/password, Login.gov, or ID.me credential to gain access to the BSO application.

Registering for an account with the IRS for filing your 1099s

If this is the first time that you will be filing your 1099s or other information returns with the Internal Revenue Service, you will need to complete an IRIS Application for TCC which will allow you to e-file your 1099s (or other information returns). It is free and you do not need special software to use this system. The IRS states that you should allow up to 45 days for processing, so this should be completed as soon as possible. You will need to validate your identity using ID.me, and an SSN or ITIN, and individual authentication is required. Please note that in previous years, the IRS used the Filing Information Returns Electronically (FIRE) system to file 1099s, and before it is totally replaced by IRIS, the FIRE system will remain available for bulk filing Form 1099 series and other information returns at least through the 2024 filing season. The IRS has announced that the FIRE system will be down from 3 PM November 22, 2024 until January 13, 2025, for annual updates.

W-2 File Specifications

See Specifications for Filing Forms W-2 and W-2c (ssa.gov) for file specifications for electronic filing Form W-2 with the SSA.

1099 Filing Instructions

See Publication 5717 (Rev. 11-2022) (irs.gov) for information on how to file the 1099s through the IRS Information Returns Intake System (IRIS). Additional filing guidelines for 1099s using the FIRE system can be found at Publication 1220 (Rev. 9-2023) (irs.gov).

Filing Deadlines

The deadline to submit the W-2s to the SSA is January 31, 2025, whether you file electronically or use paper forms. The most common 1099s, the Form 1099-NEC, Nonemployee Compensation and Form 1099-MISC, Miscellaneous Information, are both are due to the recipients by January 31, 2025. Form 1099-NEC also must be filed with the IRS by January 31, 2025, regardless of whether filed in paper or electronically. Form 1099-MISC must be filed by filed by February 28, 2025 if filed on paper, or March 31, 2025 if you file electronically.

A 30-day extension can be obtained by filing the Form 8809 (Application for Extension of Time to File Information Returns) with the IRS. For Forms W-2 or 1099-NEC, you must be able to show that there are extenuating circumstances that are preventing you from filing by the stated due date. Examples of such circumstances are:

A catastrophic event in a Federally Declared Disaster Area
A fire, casualty or natural disaster that affected the operation of the business.
A death, serious illness, or unavoidable absence of the individual responsible for the filing the information returns.

This extension cannot be used to request an extension of time to give employees or payees copies of their W-2s or 1099s.

If you will be unable to comply with the threshold reduction due to experiencing a hardship, you can submit a Form 8508, Application for a Waiver from Electronic Filing of Information Returns.

Pennsylvania Electronic Filing Requirements

Pennsylvania also requires that the W-2s and 1099s be filed electronically through the Pennsylvania myPATH system if you have a combined 10 or more of the forms. If you do not have a myPATH account, it is recommended to sign up for an account as early as possible to ensure that you are prepared for electronically filing your year-end W-2s and 1099s. Both W-2s and 1099s must be filed electronically before you can file the Annual Withholding Reconciliation Statement (REV-1667). The W-2s and 1099s are due by January 31, 2025. The file specifications for uploading the W-2s and 1099s can be found by visiting this link: myPATH Employer Withholding Multi-Import/File Upload File Specifications page.

Please reach out to your trusted Herbein advisor if you have questions regarding this article or any year-end tax reporting questions.

Article Contributed by Michelle Sowers