When must information returns be filed electronically?

Effective January 1, 2024, the electronic filing threshold is 10 or more returns (down from 250). This threshold applies in aggregate across all return types (1099s, W-2s, 1095s, etc.). Filers with fewer than 10 returns may file on paper with Form 1096. [IRC §6011(e)]

What is Form 1096 used for?

Form 1096 is the paper transmittal form that accompanies paper information returns filed with the IRS. A separate Form 1096 is required for each type of information return (e.g., one for 1099-NEC, one for 1099-MISC, one for 1099-INT). Electronic filers do NOT file Form 1096 — the electronic submission serves as the transmittal.

What are the penalties for late filing of information returns?

Penalties per return: $60 if filed within 30 days; $130 if filed after 30 days but by August 1; $310 if filed after August 1 or not filed. Maximum annual penalties: $1,261,000 (small businesses with gross receipts ≤$5M); $3,783,000 (large businesses). Intentional disregard: $630 per return with no maximum. [IRC §6721]

What is the difference between the IRS filing deadline and the recipient furnishing deadline?

Recipient furnishing deadline: January 31 for most 1099s (including 1099-NEC, W-2). IRS filing deadline: January 31 for 1099-NEC and W-2; February 28 (paper) or March 31 (electronic) for most other 1099s. The earlier January 31 deadline for 1099-NEC was implemented to combat fraudulent refund claims.

Can I correct a 1099 after filing?

Yes. File a corrected 1099 by checking the 'CORRECTED' box at the top of the form. File a new Form 1096 with the corrected return (mark it 'CORRECTED' as well). For electronic corrections, use the same filing method as the original. Corrections must be made promptly — penalties are reduced for timely corrections.

IRS Form — Annual Summary and Transmittal

Form 1096 — Annual Summary and Transmittal of U.S. Information Returns

Form 1096 is the transmittal form used to submit paper information returns (1099s, W-2Gs, 1098s) to the IRS. It is not required when filing electronically. For tax professionals, Form 1096 is a routine administrative form — but understanding the deadlines, the electronic filing threshold, and the penalties for late filing is important for compliance.

✓ Verified 2026 Form 1096 Rules

✓ Electronic Filing Threshold Confirmed

✓ Late Filing Penalty Confirmed

✓ 1099-NEC Deadline Confirmed

February 28

Paper Filing Deadline (Most 1099s)

March 31

Electronic Filing Deadline (Most 1099s)

10 Returns

Electronic Filing Required if 10+ Information Returns

IRC §6721

Information Return Penalty Authority

Key Rules and Authority

Rule	Detail
Paper Deadline (most 1099s)	February 28
Electronic Deadline (most 1099s)	March 31
1099-NEC Deadline	January 31 (paper and electronic)
Electronic Filing Threshold	10+ returns (reduced from 250 in 2024)
Late Filing Penalty	$60–$660 per return (2026, indexed)
Intentional Disregard	$660 per return minimum

Electronic Filing Threshold — Now 10 Returns

Starting with returns filed for tax year 2023, the IRS reduced the electronic filing threshold from 250 to 10 information returns. This means any filer who submits 10 or more information returns (counting all types — 1099-NEC, 1099-MISC, W-2, 1098, etc.) must file electronically using the IRS FIRE system or an approved e-file provider. Paper Form 1096 is only required for filers with fewer than 10 information returns. The electronic filing requirement applies per filer (EIN) — not per form type. A business that files 6 Forms 1099-NEC and 5 Forms 1099-MISC has 11 total returns and must file electronically.

Frequently Asked Questions

My client filed paper 1099s when they were required to file electronically. What is the penalty?

Filing paper returns when electronic filing is required is treated as a failure to file — the penalty is $60 per return for returns filed within 30 days of the deadline, increasing to $120 per return if filed more than 30 days late but before August 1, and $310 per return if filed after August 1 or not filed at all (2026 amounts, indexed for inflation). The maximum annual penalty is $3,532,500 for large businesses ($1,177,500 for small businesses). However, the IRS may waive penalties for first-time failures with reasonable cause. The client should file the corrected electronic returns as soon as possible and attach a reasonable cause statement to request penalty abatement.

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Form 1096 — Annual Summary and Transmittal of U.S. Information Returns

Key Rules and Authority

Electronic Filing Threshold — Now 10 Returns

Frequently Asked Questions

Master Information Return Compliance for Your Clients

Related Resources

Free Access for Tax Professionals

Form 1096 — Annual Summary and Transmittal of U.S. Information Returns

Key Rules and Authority

Electronic Filing Threshold — Now 10 Returns

Frequently Asked Questions

Master Information Return Compliance for Your Clients

Related Resources