Understand the 1099-K reporting threshold rules and their impact on payment processor obligations

Steps

1. Review the current IRS guidance on 1099-K reporting thresholds; the threshold has been subject to change through IRS notices and transition relief announcements — verify the threshold applicable to the current and upcoming tax years directly from IRS.gov or IRS notices rather than from prior-year knowledge
2. Identify which entities are third-party settlement organizations (TPSOs) or payment card organizations with 1099-K obligations; these include payment processors, marketplaces, and payment networks that settle third-party transactions
3. For platforms above the threshold, implement payee data collection (legal name, TIN, address) sufficient to complete the 1099-K; this typically means collecting Form W-9 from US payees and appropriate W-8 from non-US payees at onboarding
4. Implement logic to aggregate reportable payments per payee per calendar year, tracking both the total dollar amount and (where applicable) the transaction count against the applicable threshold
5. Generate and distribute 1099-K forms to payees by the applicable furnishing deadline and file with the IRS by the applicable filing deadline; these deadlines are published in the IRS General Instructions for Certain Information Returns each year
6. For state 1099-K reporting, be aware that some states have their own reporting thresholds that may differ from the federal threshold; check each state's requirement for 1099-K filing and direct-to-state filing obligations