Electronic filing required for W-2s, 1095s, 1099s: But what about 941s?

When IRS reduced the electronic filing threshold, the change impacted a long list of information returns. Now, the list of forms to e-file may get longer.

That’s because of a recent recommendation from the Electronic Tax Administration Advisory Committee (ETAAC).

In its Annual Report to Congress, released in June 2023, ETAAC pushed for the electronic filing of Form 941 and other forms in the 94X series.

IRS should provide a portal for filers to upload original and amended 94X returns, ETAAC recommended in its report. Furthermore, the portal should be made available by January 1, 2024.

Of course, that’s the same time the lower threshold will kick in for many other information returns.

The ETAAC report commended IRS for its regulations which set the new e-filing threshold at 10 returns in aggregate. The regs cover a wide range of forms – from W-2s to 1095s to 1099s.

But not 941s.

IRS has taken some steps toward change, as ETAAC pointed out in its report. IRS Tax Tip 2023-72 mentions that a mobile-friendly way to file forms 940, 941 and 944 is coming.

Options for electronic filing

In addition to the portal, ETAAC’s report presented other ideas related to the electronic filing of Form 941.

One was that IRS could create an option for line-by-line input. The report compares this to a method available for filing Forms W-2 through the Social Security Administration’s Business Services Online. With this, authenticating filers using a Transmitter Control Code would be important.

The final idea was that IRS could come up with a way to download and automatically upload a PDF, or other image of a 941, to the IRS system.