Must You E-File 1099-NECs? The 10-Return Rule

October 17, 2026 · 3 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 for 2027 and later are expected. Examples use made-up numbers. This page contains no affiliate links.

Short answer: The Instructions for Forms 1099-MISC and 1099-NEC (12/2026) say T.D. 9972 lowered the e-file threshold to 10 returns, calculated by aggregating all information returns, for returns required to be filed on or after January 1, 2024. The IRS IRIS page says the same: starting tax year 2023, with 10 or more information returns you must file electronically, including Forms W-2 e-filed with the SSA.

What this means for 1099-NEC payers

• The count is all information returns together (for example 1099-NEC, 1099-MISC, 1099-K, W-2), not per form type. Five 1099-NECs plus five W-2s reaches 10.
• Under 10, paper filing remains possible (paper rules).
• Due date for 2026 payments: January 31, 2027 is a Sunday, so the due date is expected to be Monday, February 1, 2027 (due date).

IRS IRIS facts (page read 17 October 2026)

• The IRIS Taxpayer Portal is free and lets you e-file up to 100 returns at a time, by manual entry or CSV upload, and download recipient copies.
• You need an IRIS Transmitter Control Code (TCC); the 5-digit code works only for IRIS.
• For software, IRIS A2A handles larger files (up to 100 MB at a time).
• Notice on the page: from October 7, 2026, IRIS transmissions for tax years 2022-2026 must use SchemaVersionNum 5.0.7 (relevant to software developers).
• Form 1099-NEC for tax year 2025 can be filed in IRIS; the page lists tax-year 2025 forms as processing year 2026. We did not see a processing-year-2027 list for tax year 2026.

Practical checklist

1. Count every information return you will file for 2026.
2. If 10 or more, apply for an IRIS TCC early (the IRS page does not state processing time).
3. Collect TINs with Form W-9 first (W-9 guide).
4. Furnish recipient copies by the same date; truncating a recipient's TIN on the statement is allowed, not on the IRS filing. For a comparison of IRIS and software, see this guide.

FAQ

Is there a waiver?

Pub. 1099 covers waivers and hardship; we did not read it.

What if I file late?

See penalties and extensions.

What we could not verify