The IRS requires electronic filing once you reach 10 or more information returns in a calendar year. That count combines nearly all form types together: W-2s, 1099-NECs, 1099-MISCs, and others all add up toward the same threshold.
Since tax year 2023, the IRS requires electronic filing for any filer who issues 10 or more information returns in a calendar year. The key word is aggregate: the IRS does not count each form type separately. It adds them all up.
Before 2023, the threshold was 250 returns per form type. A business filing 200 W-2s and 200 1099-NECs was under the 250-form threshold for each type individually and could paper file both. Under the current rule, those same 400 returns far exceed 10, and all of them must be eFiled.
The regulation is codified at 26 CFR section 301.6011-2, finalized by Treasury Decision 9972 in February 2023. It applies to returns required to be filed for tax year 2023 and later.
Almost all information return types covered by the regulation count. The list includes:
This list is not exhaustive. For the complete list of covered returns, see the IRS General Instructions for Certain Information Returns at IRS.gov.
W-2s count toward the aggregate even though they are filed with the SSA, not the IRS. If you have 7 W-2s and 3 1099-NEC forms, your total is 10. All 10 must be eFiled, the W-2s through SSA Business Services Online (BSO), and the 1099s through IRIS.
The table below shows how the aggregate count works across different combinations of form types.
| W-2s | 1099-NECs | 1099-MISCs | Other 1099s | Total | eFile required? |
|---|---|---|---|---|---|
| 8 | 0 | 0 | 0 | 8 | No — under 10 |
| 5 | 5 | 0 | 0 | 10 | Yes — all 10 forms must be eFiled |
| 3 | 4 | 2 | 1 | 10 | Yes — all 10 forms must be eFiled |
| 0 | 9 | 0 | 0 | 9 | No — under 10 |
| 25 | 12 | 3 | 0 | 40 | Yes — all 40 forms must be eFiled |
The second and third rows illustrate the most common point of confusion. Nine 1099-NEC forms alone do not require eFile. But five W-2s plus five 1099-NECs do, even though neither form type alone crosses 10.
The threshold is per employer TIN, not per preparer or payroll service provider. The total number of information returns filed under a single employer identification number is what determines whether eFile is required.
If you use a payroll service for your W-2s and handle your 1099s yourself, all those returns still count together under your EIN. Splitting the work between two vendors does not split the count. You remain legally responsible for ensuring all returns are eFiled correctly and on time.
Third-party preparers and payroll services file under their clients' TINs. Each client's total is counted separately. A preparer filing 50 returns for one client and 50 for another is not combining those two clients' returns, as each client has their own aggregate count.
Corrected returns do not count toward the 10-return threshold when determining whether eFile is required.
However, they must be filed using the same method as the original returns. If your original returns were required to be eFiled, any corrections must also be eFiled. You cannot paper file a corrected return for a form that was originally eFiled.
A rejected eFile does not count as a filed return either. If IRIS or SSA BSO rejects your submission, you must correct the error and resubmit electronically. The original rejected submission does not protect you from late-filing penalties.
The rule is based on your total returns for the full calendar year, not a snapshot at any one point. If you start the year expecting to file 8 forms and later need to file 4 more, you are now over 10 and must eFile all of them.
In practice, most businesses can anticipate their volume before filing season. Count your employees for W-2 purposes and your active contractors for 1099 purposes at year-end. If the combined total is 10 or more, plan to eFile everything.
Paper filing when eFile is required is treated as a failure to file the correct information return under IRC section 6721. The IRS can assess the standard late-filing penalties on every paper-filed return that should have been eFiled, even if those returns were submitted on time and with correct information.
The per-form penalties range from $60 to $340 depending on how late the correction is made, with no cap removed for intentional disregard at $680 per form. See IRS Penalties for Filing 1099s Late: Penalty Tiers by Delay Period for full penalty tier details.
If paper filing is a genuine hardship, you can request a waiver using Form 8508, Application for a Waiver from Electronic Filing of Information Returns. Submit it at least 45 days before your filing deadline. Waivers are not automatic and must document a qualifying hardship.
The aggregate threshold determines whether you must eFile, but it does not change where each form type goes. Two separate systems handle electronic filing.
The FIRE system is retired for filing season 2027. IRIS is now the only IRS intake system for information returns. If you or your software previously used FIRE to submit 1099s, confirm your transition to IRIS is complete before filing season begins.
Tax Forms Helper routes your filings to the correct system automatically. W-2s transmit to SSA BSO, and 1099s transmit to IRIS, without any manual routing on your part.
Run this count before year-end to know whether eFile applies to you:
When in doubt, eFile. The IRS accepts voluntary electronic filing from filers under the threshold. Filing electronically when you are not required to does not create any compliance issues.
Adams® Tax Forms Helper® handles W-2 and 1099 eFiling for both SSA and IRIS in one place. See About eFiling for step-by-step instructions.
In aggregate, across almost all information return types rather than separately per form. W-2s, 1099-NECs, 1099-MISCs, 1098s, and others all add up toward the same total. Seven W-2s plus three 1099-NECs is 10 returns, and all 10 must be eFiled.
Yes, even though they are filed with the SSA rather than the IRS. They count toward the same aggregate total as your 1099s. The forms then go to two different systems: W-2s through SSA Business Services Online and 1099s through IRIS.
Per employer TIN. The total number of information returns filed under a single employer identification number is what determines whether eFile is required. Splitting the work between a payroll service and yourself does not split the count, and you remain responsible for ensuring all returns are eFiled correctly and on time.
No, corrected returns are excluded when you determine whether eFile is required. They must, however, be filed the same way as the originals: if the original returns had to be eFiled, the corrections must be eFiled too. A rejected eFile does not count as filed either, and it does not protect you from late-filing penalties.
Subject to change. Verify at IRS.gov, SSA.gov, or the relevant government site.
In aggregate, across almost all information return types rather than separately per form. W-2s, 1099-NECs, 1099-MISCs, 1098s, and others all add up toward the same total. Seven W-2s plus three 1099-NECs is 10 returns, and all 10 must be eFiled.
Yes, even though they are filed with the SSA rather than the IRS. They count toward the same aggregate total as your 1099s. The forms then go to two different systems: W-2s through SSA Business Services Online and 1099s through IRIS.
Per employer TIN. The total number of information returns filed under a single employer identification number is what determines whether eFile is required. Splitting the work between a payroll service and yourself does not split the count, and you remain responsible for ensuring all returns are eFiled correctly and on time.
No, corrected returns are excluded when you determine whether eFile is required. They must, however, be filed the same way as the originals: if the original returns had to be eFiled, the corrections must be eFiled too. A rejected eFile does not count as filed either, and it does not protect you from late-filing penalties.
Save up to 45 days by skipping the wait for IRS processing.
Save up to 45 days by skipping the wait for IRS processing.
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Social Security Administration Direct Operations CenterWilkes-Barre, PA 18769-0001 (for Certified Mail Use ZIP code 18769-0002)
Social Security Administration Direct Operations CenterP.O. Box 3333 Wilkes-Barre, PA 18767-3333.
Reduce the 250-return threshold enacted in prior regulations to generally require electronic filing by filers of 10 or more returns in a calendar year. The final regulations also create several new regulations to require e-filing of certain returns and other documents not previously required to be e-filed.
Require filers to aggregate almost all information return types covered by the regulation to determine whether a filer meets the 10-return threshold and is required to e-file their information returns. Earlier regulations applied the 250-return threshold separately to each type of information return covered by the regulations.
Eliminate the e-filing exception for income tax returns of corporations that report total assets under $10 million at the end of their taxable year, and require partnerships with more than 100 partners to e-file information returns, and they require partnerships required to file at least 10 returns of any type during the calendar year to e-file their partnership return.
Corrections must be filed the same way the original was submitted. If you eFile the original then you must eFile the correction. If you mailed in the original then you must mail in the correction.
Do not cut or separate Copies A of the forms that are printed two or three to a sheet, except for Form W-2G. Generally, Forms 1097, 1098, 1099, 3921, 3922, and 5498 are printed two or three to an 8" x 11"sheet. Form 1096 is printed one to an 8" x 11" sheet.
These forms must be submitted to the IRS on the 8" x 11" sheet. If at least one form on the page is completed, you must submit the entire page. Forms W-2G are an exception and may be separated and submitted as single forms. Send your forms to the IRS in a flat mailing (not folded).
Do not staple, tear, or tape any of these forms. It will interfere with the IRS’s ability to scan the documents.
Pinfeed holes on the form are not acceptable. Pinfeed strips outside the 8" x 11" area must be removed before submission without tearing or ripping the form. Substitute forms prepared on continuous feed or strip form paper must be burst and stripped to conform to the size specified for a single sheet (8" x 11") before they are filed with the IRS.
Do not use a form to report information that is not properly reportable on that form. If you are unsure of where to report the data, call the information reporting customer service site at 1-866-455-7438 (toll free).
Do not submit anything other than red ink copies to the IRS.
Use the official forms or substitute forms that meet the specifications in Pub. 1179. If you submit substitute forms that do not meet the current specifications and that are not scannable, you may be subject to a penalty for each return for improper format. All of Adam’s tax forms meet the proper requirements, so use us as a resource.
Do not use dollar signs ($) (they are pre-printed on the forms), ampersands (&), asterisks (*), commas (,), or other special characters in money amount boxes.
Do not use apostrophes (’), asterisks (*), or other special characters on the payee name line.
No photocopies of any form are acceptable.
Do not print plain ink copies of your W-2 copy A or W-3 form. If a box doesn't apply to you, leave it empty.
Do not add "0".
Do not omit the decimal point and cents from entries.
Do not mistakenly check the “Retirement plan” checkbox in box 13. See page 22 of this IRS PDF for Retirement plan details.
Do not misformat the employee’s name in box e. Enter the employee’s first name and middle initial in the first box; his or her surname in the second box; and his or her suffix (such as “Jr.”) in the third box (optional).
Do not enter the incorrect employer identification number (EIN) or the employee’s SSN for the EIN.
Do not cut, fold or staple Copy A paper forms mailed to SSA.
Do not mail any copy other than Copy A of Form W2 to the SSA.
File the correct form with the correct amount, code, checkbox, name or address, and check the “CORRECTED” box. This overwrites what you originally filed with the IRS under that person or company’s name and TIN. Send the corrected form to the recipient and prepare the red Copy A to send to the IRS with the Form 1096 transmittal if you’re paper filing. If you also had the wrong recipient/payee name or TIN do a Type 2 correction instead.
For Type 2 errors, either the recipient/payee name and/or the TIN are wrong or you used the wrong form (like a 1099-MISC instead of a 1099-NEC). Action: This is a two-step process. First, you must zero out what you filed with the IRS under the wrong name/TIN and then file the new form.
Step 1
File a form with the CORRECTED box checked and the exact same payer and recipient information as on the incorrect form, but with all the amounts as zeros. This will remove the originally filed form from the IRS records.
Step 2
File a new Form 1099 with the right information as an originally filed form (not a corrected form).
Incorrect Payer Name, Payer TIN, or both Action: Write a letter to the IRS.
If you filed with the wrong payer name (yours or your client’s name/company name) or the wrong payer taxpayer identification number (TIN), you don’t need to send in a corrected form.
Instead, you should write a letter containing the following information:
Name and address of the payer
Type of error (including the incorrect payer name/TIN that was reported)
Tax year Payer TIN Transmitter Control Code (if you eFiled),
Type of return, Number of payees, Filing method (paper or eFiling)
You have exceeded the IRS paper filing threshold and are required to file electronically.
