The 2026 Tax Reporting & Withholding Conference, held in Washington, D.C., delivered a stark message to compliance professionals: the era of incremental adjustment is over.
RegTech firm Comply Exchange delved into some of the key takeaways.
IRIS transition: a new operating model, not a system upgrade
The migration from FIRE to IRIS is widely treated as a technical filing change. Comply Exchange’s makes clear that framing understates the challenge considerably. IRIS replaces post-filing error discovery with real-time validation, moves from file-level outcomes to record-level processing, and substitutes continuous monitoring for batch submission cycles.
Organisations will be required to track submission IDs, receipt IDs and individual record-level statuses, and to manage corrections within filing cycles rather than as post-season clean-up. The practical consequence: upstream data quality is now directly linked to the ability to file at all it said.
Form 1042-S grows more granular
Revisions to Form 1042-S continue to add complexity. Address fields have been expanded, with the former box 12h gaining a new field (12i) for room or suite numbers, and the prior combined city/state/country/zip field now separated into four distinct boxes.
Three new income codes have been introduced, covering consent fees, loan syndication fees and settlement payments, increasing classification pressure on filers. Parallel reporting across FIRE and IRIS continues for tax year 2025, with full IRIS migration expected thereafter.
Draft W-9 revision signals tighter upstream controls
A June 2026 revision to Form W-9, superseding a January 2026 draft, reinforces themes that ran throughout the conference. The updated form introduces expanded digital asset reporting classifications, additional certifications tied to broker activity, and tightened TIN accuracy requirements.
Reporting thresholds redrawn by new legislation
The One Big Beautiful Bill Act (OBBBA) has introduced some of the most consequential threshold changes in years. The reporting threshold for Forms 1099-MISC and 1099-NEC rises from $600 to $2,000 for calendar year 2026, indexed for inflation going forward, with backup withholding obligations aligned to the same threshold.
The 1099-K threshold has been reset to $20,000 and 200 transactions, reversing recent reductions. A new carry-forward withholding rule means that where a third-party settlement organisation was required to backup withhold in a prior year, that obligation persists into the current year if no TIN has been obtained.
Enforcement sharpens as data reconciliation deepens
IRS compliance campaigns are actively targeting Form 1042 and 1042-S filings, treaty benefit claims, intercompany payments and FATCA and TIN reporting gaps. Increased use of cross-filing data reconciliation is expanding scrutiny of documentation, workpapers and internal controls.
Comply Exchange flagged a notable operational warning from conference sessions: “soft letters” from the IRS are frequently a precursor to full examinations, not a courtesy notification.
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