IRS Announces New e-Filing Requirements for 2024

Starting January 1, 2024, IRS requirements for electronic filing (e-filing) will be expanding and will impact the filing of payroll returns, 1099s, and more. Below is an overview of the new requirements. Walz Group will continue to provide additional guidance in future communications to help you prepare for complying with these new requirements.

Overview of Final Regulations

On February 21, 2023, The U.S. Treasury Department issued final regulations concerning e-filing requirements for ” information returns,” (ex: W2, 1099 MISC, 1099 NEC, etc.) The regulations require any taxpayer filing 10 or more covered form types to file electronically or face failure to file penalties. The effective date is for all forms required to be filed after January 1, 2024. Please note that the requirement is based on the filing date of the form and not the period the form relates to. For example, an employer who must file 8 W-2 forms and 3 1099-MISC for the 2023 tax year in January of 2024 will be subject to the new requirements.

In addition to information returns, the final regulations impose e-filing requirements on persons required to file returns, including partnership returns, corporate income tax returns, unrelated business income tax returns, withholding tax returns, and certain information returns, registration statements, disclosure statements, notifications, actuarial reports and certain excise tax returns.

Covered information returns include form in the 1099 series, 1095 series, W-2 series, quarterly and annual payroll filings, 1042-S withholding forms, and other similar forms.

Walz Group CPA clients who engage the Firm to prepare covered returns other than certain payroll returns will not be impacted, as Walz Group is already filing the covered returns electronically on the client’s behalf.

A limited number of clients filing payroll returns through Walz Group will need to authorize the Firm to e-file these returns on the client’s behalf. In order to electronically file payroll returns on your behalf, we must obtain proper authorization by submitting an executed 8655 to the IRS via mail or fax. The IRS will typically process the authorization in 10-30 days.

The forms remain in effect until it is terminated, or withdrawn, meaning a new authorization will not be required each year. Additional information concerning Form 8655 will be sent to affected clients late July outlining what to expect and next steps for complying with the new regulations.

Are There Exceptions to the New e-Filing Requirements?

There are limited waivers and exemptions available on a form-by-form basis, rather than by a taxpayer-by-taxpayer basis, which will cause the failure to file penalty not to apply to the extent that the taxpayer can prove eligibility for claiming the waiver or exemption .

Primarily relief is available for:

• Filers for whom using the technology required to file in electronic form conflicts with their religious beliefs.
• Forms that are not able to be filed electronically with the IRS due to the IRS system not accepting that specific form.
• Rural and elderly filers that submit a hardship waiver request from the e-filing requirements using Form 8508. Reasonable cause relief may also be available to these filers.
• Reasonable cause relief may be available in limited circumstances.

Relief is not available for all form types covered under the final regulations.

If you have questions, please feel free to reach out your Walz Group relationship manager to discuss further OR direct your inquiries to