Year-End W-9 Checklist for Bookkeepers (Tax Year 2026)

A year-end W-9 checklist is really a plan to keep January calm. Between October and December, pull every vendor you paid in 2026, confirm a usable W-9 is on file for each one that may need a Form 1099, and chase the gaps while vendors are still easy to reach. Bookkeepers and AP teams should also plan for two changes in the 2027 filing season: the $2,000 threshold for most 2026 payments and the move from FIRE to IRIS.

General information, not tax or legal advice.

The short answer

For payments made in 2026, the general 1099-NEC and 1099-MISC reporting threshold (and backup withholding threshold) is $2,000, up from $600, according to the IRS Instructions for Forms 1099-MISC and 1099-NEC. It is indexed for inflation starting in 2027, and the 2027 amount has not been published yet.

Not everything moved: royalties stay at $10, attorney gross proceeds at $600, and backup-withheld payments are reportable at any amount.

The last day to file through the IRS FIRE system is November 19, 2026, at 3 p.m. ET; after January 1, 2027, IRIS is the only IRS e-file system for information returns.

We recommend starting W-9 cleanup in October and applying for an IRIS Transmitter Control Code now if you need one. For collecting W-9s at the start of a vendor relationship, see our vendor onboarding checklist. This post covers the year-end sweep.

Why this matters in a real workflow

Form 1099-NEC is due to both the recipient and the IRS by January 31, whether you file on paper or electronically.

That leaves little time to discover that a vendor you paid in March never returned a W-9, or sent one with no taxpayer identification number (TIN). And unlike most information returns, Form 1099-NEC gets no automatic 30-day extension on Form 8809, only one non-automatic 30-day extension requested on paper with a qualifying reason.

Late or wrong returns cost money. For information returns due in 2027, Rev. Proc. 2025-32 sets the penalty at $60 per return if corrected within 30 days, $130 if corrected after 30 days but by August 1, and $340 after that or if never filed.

Doing the detective work in the fall turns a missing W-9 into a routine request instead of an emergency.

What the IRS says

The $2,000 threshold and the items that didn't move

You generally report nonemployee compensation on 1099-NEC when you paid a non-employee at least $2,000 during the year for services in your trade or business, and the payee is an individual, partnership, estate or, in some cases, a corporation.

For 2026, most 1099-MISC boxes use the $2,000 threshold, including rents, prizes and awards, other income and medical payments.

Some thresholds did not change under OBBBA: royalties stay at $10, attorney gross proceeds and cash for fish bought for resale stay at $600, and payments with backup withholding are reportable at any amount.

If you backup withhold from a vendor, you must file a 1099-NEC for them regardless of the amount paid, even if it's under $2,000.

Corporations: generally exempt, with exceptions

Payments to corporations, including LLCs taxed as C or S corporations, generally don't need a 1099, with important exceptions.

• Law firms. The corporate exemption doesn't apply to legal services. Report attorneys' fees (1099-NEC box 1a) or gross proceeds (1099-MISC box 10) to law firms that are corporations.
• Attorneys' fees. Fees of $2,000 or more paid in your business go in 1099-NEC box 1a, and "attorney" includes law firms.
• Attorney gross proceeds. Payments to an attorney that aren't for the attorney's own services, such as settlement funds, go in 1099-MISC box 10 at $600 or more.
• Medical and health care. Payments of $2,000 or more are reportable even when the provider is a corporation. Payments to pharmacies for prescription drugs, and to tax-exempt or government hospitals, are not.

Line 3a is the federal tax classification of whoever is named on line 1 of the current Form W-9.

Card and payment-app payments

Payments you make by credit card or through third-party payment networks are reported by the payment settlement entity on 1099-K. You don't report them on 1099-NEC or MISC.

Missing TINs and backup withholding

• You must make an initial request for the payee's TIN when the account is opened or the transaction occurs. If you don't get it, backup withholding begins, according to IRS Publication 1281.
• The IRS treats a TIN as missing if it isn't provided or is obviously wrong, for example not nine digits or containing letters.
• The IRS says you must withhold 24% from reportable nonemployee compensation if the payee hasn't provided a TIN as required, or if the IRS notifies you the TIN is incorrect and the payee doesn't certify it as required (IRS: forms and taxes for independent contractors). Payers report backup withholding on Form 945.
• If you didn't get a TIN at onboarding, the reasonable-cause regulation calls for a first annual request by December 31 of the year the account opened, or by January 31 for accounts opened in December.
• If the first annual request fails, make a second one by December 31 of the following year.
• If the payee never gives you a TIN, the IRS General Instructions for Certain Information Returns say to leave the recipient TIN box blank on the 1099, and backup withholding may apply.

TIN Matching (optional, for eligible payers)

IRS TIN Matching is available only to payers, and their authorized agents, that file information returns (IRS TIN Matching).

You register for IRS e-Services and apply as an authorized payer.

Interactive TIN Matching checks up to 25 name/TIN combinations per request with immediate results. Bulk matching handles up to 100,000 combinations, with results within 24 hours (IRS TIN Matching tools).

Information from the IRS TIN Matching program must be kept confidential.

The W-9 requester instructions say program participants can generally rely on a verified TIN/name match as reasonable cause for penalty purposes.

Electronic filing: FIRE is closing, IRIS is next

If you file 10 or more information returns in total, all types combined, you must e-file (IRS Publication 1099).

Current FIRE users must apply for an IRIS Transmitter Control Code (TCC) and move to IRIS to file 2026 returns in 2027 (IRS FIRE page).

To use the IRIS portal you need a 5-digit IRIS TCC. The IRS says a typical application is processed within 45 business days, though times vary (E-file information returns with IRIS).

2027 due dates for 2026 returns

The IRS says to use the December 2026 revisions of Forms 1099-MISC and 1099-NEC to file 2026 information in early 2027.

Form 1099-MISC goes to recipients by January 31. It is due to the IRS by February 28 on paper, or March 31 if e-filed.

If a due date falls on a Saturday, Sunday or legal holiday, the due date moves to the next business day.

Applying that rule to 2027 is our calculation, not a date the IRS has printed. January 31, 2027 and February 28, 2027 are both Sundays, so the practical dates are Monday, February 1, 2027 (1099-NEC, and most 1099-MISC recipient copies) and Monday, March 1, 2027 (paper 1099-MISC). The e-filed 1099-MISC date, March 31, 2027, is a Wednesday. Confirm on IRS.gov/TaxCalendar.

Recipient copies of 1099-MISC with amounts in box 8 or 10 (including attorney gross proceeds) are due February 15. February 15, 2027 is Presidents' Day (Washington's Birthday), a federal legal holiday, so the date should roll to Tuesday, February 16, 2027. That is also our calculation; confirm on IRS.gov/TaxCalendar.

Some IRS pages still say $600

Several IRS pages still show the old $600 / 1099-MISC rule for contractor payments, including the Charities 1099 page, Pub 1828 (2015) and a tip in Pub 525 (2025). For 2026 payments, the current rule is in the December 2026 1099-MISC/NEC instructions.

Recommended workflow

These are our recommendations, not IRS rules. In a one-person practice, one person owns every step.

1. Pull the 2026 vendor payment list (AP lead, early October). Export every 2026 payee with year-to-date totals by payment method, so card and payment-app payments can be set aside.
2. Flag likely 1099 vendors (bookkeeper). Mark non-corporate service vendors at or near $2,000. Separately flag attorneys and law firms, medical providers, royalty payees and anyone you backup withheld from.
3. Audit the W-9 on file (bookkeeper). Confirm each flagged vendor has a W-9 with a line 1 name, a TIN and a tax classification. Check corporations against the exceptions above.
4. Request what's missing (AP lead, by late October). Send a secure W-9 request. Our guide on how to request a W-9 from a vendor has wording you can adapt.
5. Escalate non-responders (controller or owner, November). Apply your firm's payment-hold policy and talk with your tax adviser about backup withholding for vendors still missing a TIN.
6. Decide on TIN Matching (owner, November). If you're eligible, consider checking name/TIN pairs before January.
7. Confirm your e-file route (owner, now). At 10 or more returns, confirm you have an IRIS TCC or a provider filing through IRIS.
8. Freeze and file (bookkeeper, January). Lock 2026 totals and file ahead of the dates above.

Exception path. If a vendor still hasn't provided a TIN when you file, don't hold the whole batch. Document every dated request, follow the blank-TIN-box instruction and backup withholding rules above, and involve your tax adviser.

Example scenario

Example scenario: Maple Ledger Bookkeeping, a made-up two-person firm, handles AP for a small design studio. On October 6, the bookkeeper exports 2026 payments. Card payments to a stock-photo marketplace come off the list (1099-K). Nine service vendors are at or near $2,000. A law firm billed $1,400 in fees, below the $2,000 fees threshold, but it also received $900 in settlement funds that were not for its own services. That falls under the separate $600 gross-proceeds rule, so the firm stays on the list despite being incorporated.

Two vendors have no W-9. A third sent one with only a DBA name and an unreadable TIN (XX-XXXXXXX). The bookkeeper sends secure requests to all three, logs the dates, and follows up November 3. One vendor is still silent in mid-November, so the owner talks with the studio's CPA about backup withholding before the December payment run. By January 4, the returns are ready for review, well ahead of the February 1, 2027 date (our calculation; confirm on IRS.gov/TaxCalendar).

Common mistakes

• Dropping every vendor under $2,000. Attorney gross proceeds, royalties and backup-withheld payments follow different rules.
• Treating "Inc." as a free pass. Law firms and medical providers can still need a 1099.
• Counting card payments toward NEC totals. Those are reported on 1099-K by the payment settlement entity.
• Waiting until January for the IRIS TCC. The IRS says a typical application is processed within 45 business days, and times vary.
• Chasing W-9s by plain email. Standard email attachments are usually a poor channel for documents containing TINs: they linger in inboxes and are easy to forward to the wrong person. See secure W-9 collection for alternatives.

Checklist

Our recommended month-by-month sweep. For collection steps in more depth, see our W-9 collection checklist guide.

October

• ☐ Export all 2026 vendor payments with year-to-date totals and payment method
• ☐ Flag vendors at or near $2,000, plus attorneys, medical providers, royalty payees and any vendor you backup withheld from
• ☐ Confirm each flagged vendor has a W-9 with name, TIN and tax classification
• ☐ Send secure W-9 requests for every gap and log the date sent
• ☐ If you'll file 10+ returns yourself, apply for an IRIS TCC

November

• ☐ Follow up with non-responders, log each attempt, and review them with your tax adviser
• ☐ Decide whether to use IRS TIN Matching, if eligible
• ☐ Note November 19, 2026, the last day to file through FIRE

December

• ☐ Re-run the payment list after the last check run and catch vendors who crossed $2,000
• ☐ Make first annual TIN requests for 2026 accounts still missing a TIN
• ☐ Confirm IRIS access (or your filing provider) is ready

January

• ☐ Lock and reconcile 2026 totals; prepare returns on the December 2026 revisions
• ☐ Furnish and file 1099-NEC before the February 1, 2027 practical date (our calculation; confirm on IRS.gov/TaxCalendar)
• ☐ Calendar the 1099-MISC dates, including the later date for box 8 or 10 recipient copies
• ☐ Save the dated request history with your workpapers

How W9Vault supports this workflow

W9Vault gives each vendor a secure upload link that expires after 7 days. Files are encrypted in the vendor's browser before upload, so our server never receives the plaintext file. One request can ask for several documents at once, such as a W-9 plus an ACH authorization form (PDF, JPG or PNG, up to 20 MB). Your dashboard shows each request as sent or completed, which gives you a clear follow-up list. Files are deleted automatically 30 days after upload for completed requests, so save the W-9 to your own records before then.

W9Vault is designed to support a secure collection workflow; the customer remains responsible for their own tax, recordkeeping and security obligations.

Frequently Asked Questions

What is the 1099 threshold for payments made in 2026?

The general 1099-NEC and 1099-MISC threshold is $2,000, up from $600. Royalties stay at $10, attorney gross proceeds at $600, and backup-withheld payments are reportable at any amount.

Do I need a W-9 from a vendor I paid less than $2,000?

IRS rules call for an initial TIN request when the account is opened, before you know the year-end total. We recommend a W-9 on file for every U.S. vendor, since special thresholds and backup withholding can bring a smaller payee into scope.

When are 2026 Forms 1099-NEC due?

Form 1099-NEC is due to recipients and the IRS by January 31. Because January 31, 2027 is a Sunday, our calculation is that the practical date is Monday, February 1, 2027. Confirm on IRS.gov/TaxCalendar.

Does W9Vault check TINs against IRS records?

No. W9Vault collects documents through secure, expiring upload links. TIN Matching is a separate IRS program for eligible payers.

Official resources

• Instructions for Forms 1099-MISC and 1099-NEC (Rev. December 2026)
• Publication 1099 (2026), General Instructions for Certain Information Returns
• General Instructions for Certain Information Returns (2025)
• Form W-9 (Rev. March 2024)
• Instructions for the Requester of Form W-9
• Forms and associated taxes for independent contractors
• Publication 1281, Backup Withholding for Missing and Incorrect Name/TIN(s)
• 26 CFR 301.6724-1, reasonable cause and TIN solicitations
• TIN Matching (tax professionals)
• TIN Matching tools
• Filing Information Returns Electronically (FIRE)
• E-file information returns with IRIS
• Form 8809, Application for Extension of Time To File Information Returns
• Internal Revenue Bulletin 2025-45 (Rev. Proc. 2025-32)
• Charities: Information returns (Forms 1099)
• Publication 1828
• Publication 525 (2025)