This week on Information Return Intelligence, we break down one of the most overlooked areas of 1099 compliance: electronic delivery to recipients.

Most organizations are used to thinking about e-filing with the IRS—but what about actually getting the form to the recipient? If you’re emailing PDFs of 1099s (and let’s be honest, most people are), there’s a good chance you’re not fully compliant with IRS rules.

In this episode, Jason walks through:

Why 1099 e-delivery rules are tied to W-2 regulations
What the IRS actually says about furnishing statements electronically
The three key requirements: consent, format, and notification
Why a simple “sure, email it to me” isn’t enough
How major e-filing platforms handle compliance (and why it matters)
The real-world risk of ignoring these rules—even if “everyone else is doing it”

The takeaway? This isn’t a gray area. The rules exist, they’re detailed, and they’re enforceable—even if they’re widely ignored.

If your current process involves emailing 1099 PDFs without a formal consent workflow, this episode will make you rethink that approach.

Key Topics Covered
IRS Publication 1099 and electronic furnishing rules
Reg. §31.6051-1 and its application to 1099s
Recipient consent requirements (and why they’re more complex than expected)
Substitute statement formatting (Pub. 1179)
Website posting and notification requirements
Practical compliance strategies for AP teams and tax professionals
Who Should Listen
Accounts Payable professionals
Tax practitioners and accountants
Anyone responsible for issuing Forms 1099 or W-2
Organizations using (or considering) electronic delivery methods
About the Show

Information Return Intelligence is a fast-moving weekly podcast focused on Forms 1099, W-9, 1042-S, and everything in the world of information reporting—brought to you by IOFM.

This week on Information Return Intelligence, Jason Dinesen breaks down a developing story from the Treasury Department and IRS that could significantly impact how organizations deliver 1099s—and other information returns—to recipients.

The Treasury has issued proposed regulations to simplify electronic delivery (eDelivery) for Form 1099-DA (digital assets), while the IRS is simultaneously requesting public comments on expanding those changes to other forms, including Form 1099-B—and potentially all 1099s.

But here’s the bigger issue:
Most organizations don’t realize that emailing a PDF of a 1099 isn’t automatically compliant.

Jason walks through:

What “eDelivery” actually means under current IRS regulations
The often-overlooked consent requirements
Why the rules are considered “draconian”
What changes may be coming—and why they matter even if you don’t issue 1099-DA or 1099-B

📅 Public comments are open until May 23—this could be the beginning of major changes to how information returns are delivered.

👉 Next week: A deeper dive into the actual compliance requirements and what organizations should (and shouldn’t) be doing today.

Sponsored by IOFM (Institute of Finance & Management)
Learn more: https://www.iofm.com

In this recurring feature, we tackle various questions that people have submitted recently about 1099s and 1042-S. This episode:

--The draft of a new W-9: can you use it?
--Is FIRE really being shut down? What about file formatting in IRIS?
--Does the credit card exception apply to Form 1042-S?
--What if a vendor checks box 3b on the W-9?