1099 Preparation: What Finance and Compliance Teams Need to Know

The 1099 landscape changed in 2025. The One Big Beautiful Bill Act, signed in July, raised the 1099-NEC and 1099-MISC reporting threshold from $600 to $2,000 starting with payments made in 2026 - the first inflation adjustment since the threshold was set in 1954. The 1099-K threshold, which had been on a phased ramp down to $600, was reverted to $20,000 and 200 transactions retroactive to 2022.

The thresholds are simpler. The penalty exposure isn't. With per-form fines of up to $340 in 2026 (and $680 for intentional disregard, with no annual cap), 1099 preparation is still the area where calendar-driven processes generate the biggest financial liability. Knowing what changed, where most teams trip, and how to start in October instead of December is the difference between a steady process and a January fire drill.

What is 1099 Preparation?

1099 preparation is the process of collecting, verifying, and submitting IRS information returns that report payments made to non-employees during the tax year.

The most commonly filed form is the 1099-NEC (Nonemployee Compensation), required for any independent contractor or vendor paid above the reporting threshold in a calendar year - $600 through 2025, $2,000 for tax year 2026 and after, indexed for inflation starting 2027. Other forms in the series - 1099-MISC, 1099-INT, 1099-DIV, 1099-B, 1099-K, 1099-DA - cover different payment types.

1099 preparation involves four core activities:

• Data collection - gathering accurate taxpayer identification numbers (TINs) and legal names from payees.
• Payment reconciliation - confirming which payments trigger reporting thresholds for payees and which forms apply.
• Federal filing - submitting information returns to the IRS by the required deadline.
• State filing - determining where separate state submissions are required, beyond what the IRS handles.

Each step carries its own risks. Missing one creates downstream compliance issues that take time and resources to resolve.

What is 1099 Production, and How Does it Differ from Preparation?

1099 production is the technical step of generating the actual forms: compiling payment data, formatting it to IRS specifications, and producing print-ready or electronically transmittable output.

Preparation is the broader process - vendor outreach, W-9 collection, data validation, state filing research. Production is a stage inside that process.

Many teams use the terms interchangeably, but the distinction matters when assessing where something broke. A late form caused by formatting errors is a production issue. A late form caused by an incomplete W-9 is a preparation issue. Different fixes, different owners.

Why Does 1099 Preparation Create Compliance Risk?

The IRS imposes penalties under IRC §§6721 and 6722 for late, incorrect, or missing 1099 filings. For returns required to be filed in 2026, the per-form penalties are:

• $60 if corrected within 30 days
• $130 if corrected by August 1
• $340 if filed after August 1 or never
• $680 (minimum) for intentional disregard, with no annual cap

For an organization with 1,000 contractor relationships, missing the August 1 cutoff is a $340,000 exposure on the federal side alone. Penalties for failure to furnish a recipient copy stack on top under §6722.

Beyond the IRS, state tax agencies increasingly use 1099 data to verify income tax compliance. That creates a second layer of filing obligations many organizations underestimate. Some states require direct filing even when an organization has already submitted federally through the Combined Federal/State Filing (CFSF) program.

What Are the Most Common 1099 Preparation Mistakes?

Missing or incorrect TIN information

A 1099 is only as accurate as the vendor data behind it. If a contractor's TIN doesn't match IRS records, the filing triggers a CP2100 or CP2100A notice from the IRS, then a B Notice to the payee, then - if the payee doesn't respond within 30 days - backup withholding at 24% on every subsequent reportable payment.

The root cause is almost always incomplete W-9 collection. Organizations that wait until December to collect W-9s often receive incomplete or outdated forms - or no response at all.

Misclassifying payment types

Not every payment to a non-employee belongs on a 1099-NEC. Payments for goods, reimbursements, and certain third-party transactions fall outside reporting scope. But payments for legal services must be reported on 1099-NEC regardless of amount (the standard threshold doesn't apply), and gross proceeds paid to attorneys above $600 must be reported on 1099-MISC box 10. Misclassification produces either over-filing (extra IRS records to clean up) or under-filing (penalty exposure).

Missing state filing requirements

Federal filing doesn't satisfy state obligations. Each state sets its own rules, and they change from year to year. Multi-state operations need a clear picture of which states require direct filings, what schemas they accept, and what deadlines apply.

Late production and delivery

The IRS requires recipient delivery of 1099-NEC by January 31, and IRS filing of 1099-NEC by January 31. Most other 1099s allow until March 31 for electronic IRS filing, but recipient copies are still due January 31 or February 17, depending on the form. When production runs close to the wire, both deadlines slip together.

What Does a Strong 1099 Preparation Process Look Like?

Organizations that move through filing season smoothly share four practices.

• They collect W-9s before the payment is made. Onboarding is the right time, not Q4. Teams that build the W-9 step into accounts payable workflows cut year-end outreach volume by orders of magnitude.
• They reconcile payment data weekly, not annually. Regular reviews of contractor payments against reporting thresholds make the year-end reconciliation a confirmation step, not a discovery step.
• They map the state obligations in October. State filing requirements shift annually. Teams that confirm obligations before filing season starts avoid the scramble of figuring out state rules in January.
• They treat production as a separate workstream. Form generation has its own timeline, owner, and quality gates. Teams that conflate it with preparation are the ones whose missed deadlines cluster in the last week of January.

How Does the IRS CFSF Program Affect 1099 Preparation?

The Combined Federal/State Filing program lets organizations submit certain 1099 forms to the IRS once, and the IRS forwards the data to participating states. Roughly 30 states participate.

Several states require direct state filing outside CFSF, including Pennsylvania, Connecticut, and Massachusetts, each with their own e-file portals and schemas. States without personal income tax - including Florida, Nevada, Texas, Washington, and Alaska - generally don't require 1099-NEC filing at all. Illinois doesn't participate in CFSF for 1099-NEC but only requires direct filing when state withholding is reported.

For multi-state organizations, a complete preparation checklist includes state-by-state participation status, withholding thresholds, and schema requirements - not just federal filing dates.

What Tools and Systems Support 1099 Production?

1099 production can be handled through several channels, depending on size, payee volume, and existing infrastructure.

• Payroll and accounting platforms such as ADP, Gusto, and QuickBooks include built-in 1099 generation for contractors paid through those systems. Workable for organizations whose contractor payments flow through a single platform.
• IRS e-filing systems. Organizations filing 10 or more information returns (across all form types combined) must file electronically. The IRS FIRE system has been the long-running channel; the IRS plans to retire FIRE after filing season 2026, with the Information Returns Intake System (IRIS) as the successor for filing season 2027 onward.
• Compliance platforms like Eisen support the full preparation and production workflow - vendor data management, W-9 collection, real-time TIN matching, multi-state filing, and recipient delivery - in one system. Useful for organizations managing large payee populations or operating across multiple jurisdictions.

When Should Organizations Start 1099 Preparation?

Earlier than most teams currently do.

Effective preparation starts at vendor onboarding and continues year-round. The formal preparation timeline - reconciling payments, validating vendor data, confirming state obligations, running TIN matching against IRS records - should begin no later than November 1. That runway resolves TIN mismatches, gathers missing W-9s, and addresses state filing questions before December close creates additional pressure.

January is for production, delivery, and filing. It's not for solving data problems that could have been addressed in October.

Moving Forward with Confidence

1099 preparation rewards structure. Organizations that invest in clean vendor data, consistent reconciliation, and a clear view of state obligations move through filing season with fewer errors, fewer penalties, and less last-minute pressure.

Eisen brings that structure: W-9 solicitation with timestamped documentation, real-time TIN matching against IRS records, federal e-filing through FIRE today and IRIS as it rolls out, multi-state filing in the same workflow, and a per-payee audit trail ready for any IRS inquiry.

Reach out to us to learn how Eisen can support your reporting workflows.