1099-NEC and the Combined Federal/State Filing Program

October 17, 2026 · 5 min read

General information, not tax, legal or financial advice. We are not the IRS. Check IRS.gov or a qualified tax professional. Sources read on October 17, 2026. Dates and amounts after 2026 are expected. Examples use made-up numbers. This page contains no affiliate links.

Short answer: The IRS says the Combined Federal/State Filing (CF/SF) Program forwards information returns filed electronically to participating states free of charge for approved filers, and that Form 1099-NEC is one of the eligible forms (IRS Topic no. 804 and Pub. 1220). The IRS says that beginning with tax year 2026 the Information Returns Intake System (IRIS) is the only system for e-filing information returns; FIRE is not available for submissions in the 2027 filing season (IRS Pub. 1099). Pub. 1220 says some participating states require separate notification, that the IRS acts as a forwarding agent only, and that each state's requirements are subject to change by the state. The instructions for Forms 1099-MISC and 1099-NEC say boxes 5-7 (state information) are for your convenience and need not be completed for the IRS.

Key points from the IRS pages

• Approval for 2026 returns (filed in 2027). To use CF/SF through IRIS, the IRS says you must select the CF/SF option and consent to disclosure of data to the participating states in your IRIS TCC application, then tick the CF/SF box on the payments page and select the states that apply (IRS Pub. 5717, Rev. 9-2026). Older IRS pages (Topic 804, Pub. 1220 for tax year 2025) still describe FIRE test files, which do not apply to 2026 returns.
• Changes of state participation: the IRS says a state change requested before January 1 takes effect only the following year (Pub. 1220, section 12.02; not re-checked for 2027).
• Two states: if a payee has a reporting requirement for more than one state, separate records are created for each and amounts are prorated, not duplicated.
• Codes: states are identified by two-digit codes in Pub. 1220, not abbreviations.
• States change their rules: Pub. 1220 says each state's requirements are subject to change by the state.
• Participating states: Pub. 1220 (Rev. 5-2026, tax year 2025) and Pub. 5717 (Rev. 9-2026) list these 32 participants: Alabama, Arizona, Arkansas, California, Colorado, Connecticut, Delaware, District of Columbia, Georgia, Hawaii, Idaho, Indiana, Kansas, Louisiana, Maine, Maryland, Massachusetts, Michigan, Minnesota, Mississippi, Montana, Nebraska, New Jersey, New Mexico, North Carolina, North Dakota, Ohio, Oklahoma, Pennsylvania, Rhode Island, South Carolina and Wisconsin. States and the District of Columbia not listed (for example Missouri and Oregon) are not in the program; if your payee is in one of them, check the state's own rules. Verify against the current IRS publications before filing.

IRIS

The IRS publishes the same list of participating states in its IRIS guide (Pub. 5717), and says IRIS uses the same CF/SF process as FIRE. The IRS still acts only as a forwarding agent: you must check each state's own filing requirements.

Boxes 5-7 and paper state copies

Use boxes 5-7 to show up to two states and any state tax withheld; if a state requires a paper copy, use Copy 1 for the state tax department and give Copy 2 to the recipient (recipient and state copies).

Dates

Form 1099-NEC is due January 31; for 2026 payments, January 31, 2027 is a Sunday, so the next-business-day rule is expected to make it Monday, February 1, 2027 (due date).

Related

Filing online: IRIS vs software · E-file threshold · Corrections

FAQ

Does CF/SF replace my state filing in every state?

No; some states require separate notice and the IRS is only a forwarding agent.

Is the program free?

The IRS describes it as free of charge for approved filers.

What we could not verify