1099 Filing Checklist Template

Start with everyone the business paid during the year. A payment generally counts as nonemployee compensation, reported on Form 1099-NEC¹, when all four of these are true:

• The payee isn't your employee.
• You paid for services in the course of your business, nonprofits and government agencies included.
• The payee is an individual, partnership or estate, or in some cases a corporation.
• You paid them at least $2,000 during the year.

Some payments need no form even above $2,000. Payments to a corporation, including an LLC taxed as one, generally need no form, though lawyers and medical providers still get one. Payments for goods, freight, storage and phone service are exempt. So are payments by card or through a third-party payment network, which belong on the processor's Form 1099-K. Checks, cash and bank transfers still count.

Then confirm each payee really is a contractor. The IRS weighs behavioral control, financial control and the type of relationship², and says to document each factor. If someone works your hours, with your tools, for you alone, run a contractor vs employee classification check first.

Ask each new payee for Form W-9 before the first payment. It gives you their legal name and taxpayer identification number (TIN). IRS Publication 1281 says to ask for the TIN when the transaction occurs³, and to start backup withholding if none arrives. You hold back 24% of each payment, even from a contractor still waiting for a number.

A W-9 doesn't prove the number is right. The IRS's TIN Matching service⁴ checks name and TIN pairs against its records before you file. Payers and their authorized agents apply through an IRS account. A first-time filer may not qualify, since the IRS only admits payers that filed Forms 1099 within the last two years.

Check names as closely as numbers. For a sole proprietor, the owner's own name goes on the first name line⁵, with any business name on the second. A single-member LLC that hasn't chosen corporate tax treatment works the same way.

Add up what you paid each payee in the calendar year, not what they invoiced. Include parts and materials supplied with a service, and travel costs you reimbursed that the contractor didn't account for. The line that triggers a form differs by box¹:

A business filing 10 or more information returns in a year must file them electronically⁶, counting Forms W-2 along with every 1099. If the bakery above has eight employees, its two 1099s and eight W-2s make 10, so it must e-file. A bookkeeper counts each client separately.

For 2026 forms, the IRS accepts e-filed 1099s only through IRIS, its Information Returns Intake System. The older FIRE system shuts down at the end of 2026⁵. The IRIS portal is free and takes typed entries or a CSV upload. It needs a Transmitter Control Code, which the IRS says typically takes up to 45 business days to issue, so apply early.

Under 10 returns, paper is allowed, but order official forms from the IRS: you can't file a Copy A printed from its website.

Form 1099-NEC has no automatic extension⁵. For most other returns, Form 8809 buys 30 days if you file it by the original due date. Penalties apply per form, separately for the IRS copy and the payee's. The IRS's latest figures, for returns due in 2026, are $60 a form up to 30 days late, $130 through August 1 and $340 after that⁶.

The IRS lists missing and mismatched TINs on a CP2100 or CP2100A notice, sent twice a year, in October and the following April⁷. Where the list agrees with your records, you have 15 business days to send the payee a B notice³ asking for the right details. If no signed W-9 comes back, start backup withholding within 30 business days of receiving the IRS notice.

A second notice for the same payee within three calendar years needs a second B notice. This time a W-9 won't do: the Social Security Administration or the IRS must validate the number. A corrected TIN alone needs no corrected 1099; use it on future forms.

A proposed penalty arrives as Notice 972CG. With reasonable cause, you have 45 days to respond⁶, and an IRS notice response letter helps you make the case.

If a CPA prepares the business's return, send the payee list with the year-end tax package for your CPA. The template on this page tracks payees, W-9s, totals by box and each client's 1099 count, and River can fill it in from your payment records.