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?

This episode recaps what happened in the 1099 and 1042-S world in the first quarter of 2026. Highlights:

--Still no new W-9, but draft W-9 instructions released
--Do Native American tribes need to issue 1099s?
--FIRE shutdown becomes clearer
--2026 drafts of 1099-NEC and 1099-MISC
--Treasury Department seeks comment on providing forms to recipients electronically
--And more!

The IRS dropped another round of draft 2026 forms on March 27th — updated versions of the 1099-NEC and 1099-MISC — and we still don't have a final version, which is notably late compared to prior years. Jason walks through what's changed in the latest drafts, including the new boxes for reporting tips and overtime pay, and a cosmetic redesign of the name and address fields that's probably not a big deal but worth keeping an eye on.

The bigger conversation this week is the why behind those new boxes: tips and overtime deductions are now available to workers on their personal returns, which means employers and payers need to break that information out on the forms they issue. For most listeners, that's a W-2 story — but Jason explains the narrow scenario where overtime or tips could legitimately land on a 1099, including the unusual situation where a worker is classified as an employee under the FLSA but treated as a contractor by the IRS.

Information Return Intelligence is sponsored by IOFM.

The IRS has been signaling for months that the FIRE system — one of its two electronic intake systems for information returns — is on its way out. But earlier 2026 drafts of Publication 1099 left some wiggle room in the language. The March 2026 draft doesn't. Jason Dinesen walks through exactly what the updated publication says, explains what FIRE and IRIS actually are and why the distinction matters, and lays out your practical e-filing options as the end-of-2026 shutdown approaches. Whether your organization files directly or through a third-party vendor, now is the time to get ready.

A followup to last week's episode, as the IRS did end up releasing an efile waiver procedure for Form 1042. But just because the procedure exists doesn't mean you should use it. To request a waiver, you'll need to demonstrate hardship, document the steps you've already taken to comply, provide a cost computation, outline your plan to e-file in the future, and have an authorized officer sign under penalty of perjury. Requests go to the IRS by fax or mail, and here's the catch: the IRS won't send confirmation letters for 2025 waivers, so if your request is denied, you may not hear about it. The stronger move? If you filed an extension before the March 17 deadline, use that six-month runway to get an e-filing solution in place.

Form 1042 is due March 16th, and e-filing it is more complicated than you might expect. Jason Dinesen explains why Form 1042 uses the IRS's MeF system instead of IRIS or FIRE, what the e-file mandate means for your organization, and why filing a Form 7004 extension is likely your best move if you don't have a clear path to electronic filing.

Sponsored by IOFM — iofm.com.