Most finance teams will read the new 1099 threshold as good news and move on. Fewer forms, less January work. That reading is half right, and the wrong half tends to surface in the last week of January, when AP is chasing W-9s from vendors paid months earlier.
For payments made after December 31, 2025, the federal reporting threshold for Forms 1099-NEC and 1099-MISC rose from $600 to $2,000. The old figure had been in place since 1954, and the new one will be indexed for inflation for calendar years after 2026. The first returns under the new rule cover this year's payments and are due February 1, 2027.
Q4 starts this week. That makes it the last clean window to fix the data these forms depend on. Here is where I would look first.
What the 2026 1099 Threshold Changed, and What It Didn't
The headline change is simple. A contractor you pay less than $2,000 in 2026 generally no longer needs a 1099-NEC. Backup withholding now keys off the same threshold.
What did not change matters more for operations:
- Some payment types kept lower thresholds. Gross proceeds paid to attorneys still trigger a 1099-MISC at $600, and royalties stay at $10.
- States did not all follow. California and Massachusetts follow the $2,000 threshold. Mississippi and Wisconsin still use $600 for state reporting.
- The e-file rule still applies. If you file 10 or more information returns across all form types, you must file electronically.
- The filing system is changing. The IRS is retiring its FIRE system. IRIS will be the only electronic filing system for information returns after January 1, 2027.
- Taxability and deductibility are unchanged. Every contractor payment still needs support in your books, whether or not a form goes out.
For a small or mid-market business, the practical result is fewer forms, more exceptions, and a new filing channel, all in the same season.
How to Handle States That Kept $600
Many companies rely on the IRS Combined Federal/State Filing program to pass their 1099s to participating states. That program can only forward forms that were filed with the IRS. A contractor paid $1,500 in a $600 state gets no federal form, so nothing reaches that state unless you file there directly.
Operationally, I would handle this in three steps:
- Keep a state trigger in AP: For vendors in states still at $600, keep a $600 flag alongside the federal $2,000 one.
- File those forms directly with the state: Use the state's own portal and file format rather than counting on the federal-state program.
- Track state deadlines separately: State due dates and e-file rules do not always match the federal ones.
Some states also require direct filing even where they follow the $2,000 threshold. Massachusetts, for example, requires 1099-NEC and 1099-MISC to be filed directly with its Department of Revenue. State rules are still moving, so confirm each state's current requirement with its revenue department or your tax advisor before year-end.
The Real Risk Sits in Your Vendor Master
Most AP systems decide who gets a 1099 based on a vendor flag and a dollar trigger. Many platforms were built with $600 set as that trigger. If no one updates and tests the setting, you either issue forms you no longer need or apply one rule to vendors who fall under different ones.
The quieter problem is behavioral. When a threshold goes up, teams tend to relax W-9 collection. That works against you. You cannot know in March which vendor will cross $2,000 by November. A vendor billed $400 a month crosses it in month five.
In finance operations, the warning sign I look for is a vendor record whose 1099 flag, tax classification, TIN, and address were set at onboarding and never reviewed again. Those records produce most of the January scramble.
A Q4 Checklist for Year-End 1099 Preparation
This is the review I would run in October, while there is still time to collect documents and correct records before year-end.
- W-9 coverage: Pull every vendor paid year to date. Confirm each has a current W-9 on file. Collect missing forms before the next payment goes out, not after December 31.
- Threshold settings: Confirm your AP or accounting system reflects $2,000 for 1099-NEC and the affected 1099-MISC boxes, while keeping the lower thresholds that still apply. Test it against a few known vendors.
- Payment classification: Check that payments map to the right form and box. Services, rent, and attorney gross proceeds are treated differently.
- Payment method: Card and third-party network payments are generally reported by the processor on Form 1099-K. Make sure they are excluded from your own 1099-NEC totals so they are not reported twice.
- Duplicate vendors: Aggregate by TIN, not by vendor name. One contractor set up twice can split payments across two records and hide that they crossed the threshold.
- State overlay: List the states where your contractors are located. Check each state's threshold and whether it requires direct filing.
- Filing route: Ask your software provider or accountant to confirm they file through IRIS this season. If your team filed directly through FIRE, you will need an IRIS Transmitter Control Code before January.
Controls That Make January Uneventful
A well-controlled 1099 process should not depend on one person remembering how it worked last year. The work belongs in the monthly close, not in a year-end project.
For a growing finance team, I would separate three responsibilities:
- Vendor setup: A W-9 is required before a vendor is activated for payment. No exceptions for urgent invoices.
- Monthly maintenance: Vendor master changes are reviewed each month, with a short log of what changed and who approved it.
- Pre-filing reconciliation: 1099 totals are tied back to the general ledger expense accounts before anything is filed. Differences are explained, not forced.
Before year-end, these are the questions I would put to your internal team or current provider:
- Who owns the vendor master, and when was it last reviewed?
- Has our system's 1099 threshold been updated, and did anyone test it?
- Which states do our contractors sit in, and what does each require?
- Who is filing through IRIS, and has that setup been confirmed?
- Can we tie every 1099 total back to the general ledger?
If any answer is unclear, that is the place to start.
How the Verity Model Applies to 1099 Readiness
Most 1099 problems are process problems that show up once a year. At Verity Services Global, we treat vendor data as part of recurring close work rather than a January task.
Our Philippine delivery team handles the steady work: W-9 follow-up, vendor master maintenance, payment classification, and monthly reconciliation of 1099-eligible spend to the general ledger. Our U.S.-based leadership reviews classification judgment calls and state exposure, and signs off before anything is filed.
That separation creates a dual quality review. The person preparing the vendor data is not the person approving it. It reduces documentation gaps and removes the key-person dependency that often sits behind a late or inaccurate 1099 season. It does not remove the need for judgment, but it puts that judgment at the right level.
Before Year-End
The higher threshold reduces the number of forms. It does not reduce the need for clean vendor data, and the first filing season under the new rule arrives alongside a new IRS filing system and uneven state rules.
If your vendor file has not been reviewed since onboarding, now is the time. Verity Services Global can review your current AP and vendor master process, identify the control gaps that tend to surface at 1099 time, and help you decide whether additional accounting or controller support makes sense heading into year-end.
This article reflects federal 1099 filing guidance as of publication (September 2026). State requirements and IRS systems referenced above are subject to change; confirm current rules with your tax advisor or the relevant revenue department before filing.