Forms 1099 and W-2: Changes in 2016 Filing Requirements

Posted on 11.09.16

Forms 1099 and W-2: Changes in 2016 Filing Requirements

Note: This article was originally published on November 9, 2016 and is intended for 2016 federal tax filing. Please visit our recent Tax articles for more up-to-date insights.


By Susan Crockett, Tax Senior Associate | Family & Executive Advisory Services Team

Until now, there were two dates to keep in mind when filing Forms W-2 and 1099:

  • January 31: Mail Forms W-2 to employees and Forms 1099 to contractors or other recipients
  • February 28: Mail paper filings of Forms W-2 to the Social Security Administration and mail paper filings of Forms 1099 to the Internal Revenue Service (IRS) (March 31 deadline for electronic filings)

Beginning with the 2016 filings, employers will now have one filing deadline for all Federal Forms W-2 - January 31. This filing date is applicable for both employee and government copies and applies regardless of whether you are filing paper or electronic returns.

The new January 31 deadline also applies to certain types of Forms 1099. If you are filing Form 1099-Misc and reporting amounts in Box 7: Nonemployee Compensation, then the new filing deadline of January 31 applies (for mailing both the recipient and IRS copies.)


If you do not report amounts in Box 7 (but have other applicable boxes on a Form 1099), then the deadline remains February 28 for paper filings or March 31 for electronic filings.  As an example, Form 1099-INT requires that the recipient copy be mailed by January 31 and the IRS copy be mailed by February 28.

Caution:  Because the IRS forms due date has been moved up, there is no longer the cushion of an extra month to file and/or make corrections before filing the government forms.

In order to meet the new accelerated filing deadlines, we recommend that you:

  • Request a completed Form W-9, Request for Taxpayer Identification Number and Certification, in order to verify the accuracy of information for independent contractors
  • Review total payments made during the year to determine who will need a Form 1099 and also that you have a Form W-9 on file
  • Review IRS Notice CP-2100A (if received) and resolve incorrect name/TIN combinations that were reported to the IRS in prior year
  • Start the Forms 1099 preparation as soon as an independent contractor has completed all work for the calendar year and total amounts paid in 2016 are finalized

For taxpayers who may have trouble meeting the new filing deadline:

Form 8809, Application for Extension of Time to File Information Returns, can be filed to request an automatic 30-day extension to file Forms 1099.  No signature or explanation is required.  This form needs to be filed by the original due date of the returns in order to get the 30-day extension.

Form 8809, Application for Extension of Time to File Information Returns, can also be filed to request a one 30-day extension to file Forms W-2.  A detailed explanation and signature is required.  The IRS will only grant the extension in extraordinary circumstances or catastrophe.

Questions on these changes? Contact your Keiter representative for clarification or Contact Us | 804.747.0000