Failing to file accurate W-2 forms on time may result in IRS penalties that impact more than the employer’s finances. These penalties can result from incorrect Social Security numbers, late submissions, missing income fields, or unapproved paper filings. Penalties often stem from the IRS’s growing reliance on digital filing systems and year-round reporting requirements. Even small mistakes can lead to substantial fines and processing delays.

Businesses that file 10 or more information returns must now e-file using the IRS-approved systems, including the Information Returns Intake System (IRIS) and the Filing Information Returns Electronically (FIRE) platform. The rules apply across all form types, including W-2 and 1099-NEC. Employers must ensure that their submissions follow approved formatting, are transmitted using a valid Transmitter Control Code (TCC), and are submitted by the due date. Without accurate preparation, taxpayers may experience processing interruptions, interest accrual, or IRS notices that require formal responses.

This article explains how to prepare, submit, and correct W-2 filings in compliance with IRS requirements. It explains how to navigate system requirements, apply for a TCC, and recognize common errors before they result in fines. If you are responsible for payroll reporting, staying informed and following IRS instructions helps reduce the risk of penalties and supports timely processing throughout the tax year.

Who Needs to File Form W-2 and Why It Matters

Employers Responsible for Wage Reporting

Any individual or organization that employs workers and withholds income tax, Social Security, or Medicare must file Form W-2 for each employee. This obligation applies to corporations, nonprofit entities, partnerships, and sole proprietors. 

The Internal Revenue Service uses the W-2 to reconcile wage reporting with individual tax returns, making accuracy essential. Failing to issue this form or providing incorrect information places the employer at risk for financial penalties and regulatory scrutiny.

Employers must send copies of Form W-2 to the employee and the Social Security Administration (SSA). The information must reflect the total wages paid, federal and state taxes withheld, and applicable retirement plan contributions. 

Inaccurate or delayed filings compromise the employer’s compliance record and impact the employee’s ability to file a complete and timely tax return. The consequences may include delayed refunds, rejected returns, and increased administrative costs.

Filing Requirements and Tax Year Considerations

Employers who issue wages during the tax year must file Form W-2 for each qualifying worker, regardless of the company’s size or industry. This obligation extends to seasonal, part-time, and full-time staff who meet the reporting threshold. The Internal Revenue Service expects all filers to meet the due date established for the calendar year. January 31 typically serves as the cutoff for SSA submission and employee distribution.

Proper W-2 filing practices help maintain accurate reporting, reduce the need for corrections, and support overall tax compliance. Employers that align with IRS filing expectations during tax year 2023 can avoid penalties and manage documentation requirements efficiently. A clear understanding of who must file, when forms are due, and how they affect employee records is essential for maintaining full compliance throughout the year.

IRS W-2 Penalties and How Much They Can Cost

The Internal Revenue Service enforces a structured penalty system for W-2 filing violations, which includes late submissions, inaccurate data, and failure to file altogether. Penalties increase based on how long the form remains unfiled and whether the error results from neglect or intentional disregard. Employers should understand the financial risks of W-2 noncompliance and how the IRS determines penalties.

  • Filing within 30 days of the deadline: Employers who submit Form W-2 no more than 30 calendar days late may receive a penalty of $60 per return. While this is the lowest tier, the cost can accumulate across multiple employees.

  • Filing between 31 days and August 1: The IRS increases the penalty to $130 per return for submissions filed between 31 days after the deadline and August 1. This often affects employers who need time to correct reporting issues or gather supporting documentation.

  • Filing after August 1 or not at all: If the employer misses the August 1 cutoff or fails to file entirely, the penalty increases to $330 per return. This applies even if the employer files paper forms without meeting the approved exemption standards.

  • Intentional disregard of filing rules: The most severe penalty, $660 per return, applies when the IRS determines the employer intentionally failed to file or knowingly submitted false or incomplete information. There is no maximum cap for this penalty type.

  • Annual limits based on business size: The IRS applies annual caps for small businesses, although those limits do not apply in cases of intentional disregard. Caps vary by tax year and filing volume.

The IRS's information return penalties overview details penalty amounts, caps, and timelines. Employers who understand each tier and penalty category are better positioned to assess risk and reduce exposure. Taking timely action, monitoring due dates, and verifying accuracy can significantly limit the potential for financial consequences.

What the IRS 10-Return Filing Rule Means for You

The Internal Revenue Service now requires electronic filing for most businesses that submit 10 or more information returns during a calendar year. This threshold applies to the total volume of returns filed across all platforms and form types, not only Form W-2. For example, an employer who submits five Forms W-2 and five Forms 1099-NEC in the same year reaches the 10-return limit and must file all information returns electronically. The policy aims to streamline reporting and improve accuracy across filing systems.

Employers must evaluate their filing volume annually and plan accordingly to meet this requirement. The rule includes forms transmitted through multiple systems, including the Information Returns Intake System (IRIS), the FIRE system, and ACA-related AIR submissions. Once the 10-return threshold is met, all forms must be filed electronically using the appropriate method. Failure to meet this condition may lead to IRS penalties unless a waiver is granted through Form 8508. Employers relying on paper submissions without an approved waiver risk penalties regardless of whether the returns were filed on time.

Accuracy in determining return totals is essential, particularly for businesses that manage filings across departments, campuses, or affiliate entities. Employers must coordinate internal processes to prevent oversight and verify return counts well before the due date. Monitoring the volume of reportable forms early in the calendar year allows adequate time to complete registration in IRS systems such as IRIS or FIRE and obtain a valid Transmitter Control Code (TCC). Returns may be rejected or delayed without proper system access or formatting compliance, resulting in penalties.

Understanding the 10-return rule supports timely and compliant submission of wage and non-wage forms. Businesses that adapt to electronic filing requirements and assess their return volume in advance reduce the likelihood of filing violations. Taking a proactive approach strengthens administrative control and ensures alignment with IRS expectations for the tax year.

Payroll Mistake #1 — TIN Mismatches and Name Control Errors

TIN mismatches occur when the taxpayer’s name and Taxpayer Identification Number do not match IRS or Social Security Administration records. These discrepancies trigger automatic rejections, delay processing, and may result in penalties under IRS information return rules. 

Employers must report accurate employee details on every Form W-2 submitted during the calendar year, including the legal name and valid Social Security Number as registered with the SSA. Incorrect data undermines return validity and may lead to formal IRS notices, such as Notice 972-CG, requiring a timely response and supporting documentation.

Common Causes of TIN Mismatches

  • Incorrect Social Security Number entry: Typing errors, misplaced digits, or transposed numbers during data entry can lead to invalid filings.

  • Unreported legal name changes: Employees who change their name due to marriage, divorce, or court order and fail to update records with the SSA contribute to TIN mismatches.

  • Use of nicknames or shortened names: The IRS requires the legal name on record. Using informal names during payroll setup may cause immediate rejection.

  • Incorrect entity name control: When submitting returns electronically, business filers must use a specific four-character name control code. Formatting errors in this field can trigger system failures.

  • Outdated internal records: Employers who do not regularly update employee profiles risk submitting incorrect information across multiple tax years.

How to Prevent TIN Matching Errors

  • Use the IRS TIN Matching tool: Employers can validate names and TINs through the IRS e-Services portal before submitting returns.

  • Review onboarding documents annually: Verifying Social Security Numbers and legal names before each tax year reduces reporting errors.

  • Align records with SSA databases: Before finalizing W-2 data, confirm that the employee’s name matches their SSA records.

  • Provide employee education: Encourage employees to notify HR of any name changes before W-2 deadlines.

  • Centralize payroll data management: To reduce inconsistency, ensure that all departments use the same validated source of employee records.

Accurate identity reporting protects both the employee and employer from IRS penalties. A thorough approach to verifying names and TINs supports compliance across the tax year and reduces the likelihood of submission errors that affect refund timing and IRS correspondence.

Payroll Mistake #2 — Incorrect File Formats and Rejected Submissions

Employers filing information returns electronically must follow strict formatting rules issued by the Internal Revenue Service. Submitting files that do not meet these technical specifications often results in rejected transmissions, late penalties, and additional administrative work. 

Although the requirement to e-file applies once an employer files 10 or more returns in a calendar year, even those below the threshold should understand the risks associated with using unapproved formats or platforms. Failing to comply with these standards delays processing and may cause the IRS to treat the filing as incomplete or noncompliant.

Required File Format Standards

  • ASCII text format only: The IRS mandates using ASCII for electronic submissions through the FIRE system. Other encoding types, such as EBCDIC, are not permitted.

  • No PDFs or image files: The agency does not accept submissions in formats like PDF, JPG, TIF, or PNG. Scanned documents uploaded through unapproved channels will be rejected.

  • Excel and Word documents not accepted: Submitting information returns in spreadsheet or word processing formats fails to meet the agency’s technical requirements.

  • Self-extracting zip files are not allowed: Files compressed using executable packaging or encryption methods will not pass system filters.

  • File naming and layout compliance: Each file must follow the character structure and positioning rules outlined in IRS Publication 1220, including proper use of record identifiers and control totals.

Recommended Steps for Format Compliance

  • Use IRS-approved software or development guidelines: Employers must follow the FIRE system’s transmission protocols for valid submission.

  • Test file structure before transmitting live data: The IRS encourages using the FIRE system test environment to identify formatting issues in advance.

  • Reference Publication 1220 for file layout: Detailed specifications are available in IRS Publication 1220, which explains formatting standards for W-2, 1099, and other returns.

Proper formatting is essential to maintaining electronic filing compliance. Employers who follow technical instructions and test files and ensure compatibility with FIRE system requirements improve submission success rates and reduce avoidable rejections during the tax year.

Payroll Mistake #3 — W-2 Box Errors and Retirement Plan Codes

Common Mistakes in Box 12 Reporting

Form W-2 Box 12 requires accurate reporting of elective deferrals and other retirement contributions using IRS-designated codes. Misreporting these entries leads to incorrect tax withholding records and may trigger audits or notices to the employer and the employee. Each code corresponds to a specific type of retirement plan, and misuse can confuse the calculation of income. 

For example, Code D applies only to traditional 401(k) contributions, while Code S is reserved for SIMPLE IRA deferrals. Using the wrong code compromises both return accuracy and employee eligibility for tax benefits. Some employers mistakenly apply Box 12 codes interchangeably or fail to report deferrals altogether. Some employers misreport 403(b) contributions under Code D when Code E is required. 

Errors arise when non-qualified plans are coded as qualified contributions or when amounts are entered for employees not participating in the listed plans. These mistakes lead to inconsistencies between employer records and employee tax returns, often requiring corrections through Form W-2c and W-3c.

Box 13 and the Retirement Plan Checkbox

In addition to Box 12, employers must correctly complete Box 13, which includes a checkbox indicating whether the employee was an active participant in a retirement plan. This designation affects eligibility for certain tax deductions and must align with plan participation records. Mismarking the checkbox due to a misunderstanding or administrative oversight can create reporting conflicts. Employers should maintain current plan enrollment documentation to ensure accurate designation.

The IRS maintains detailed guidance on common retirement plan reporting mistakes in its official reference materials. Employers can review examples and explanations provided in IRS guidance on W-2 retirement plan code errors to ensure compliance with current standards. Adhering to these rules reduces the need for corrections, supports employee transparency, and promotes compliance with IRS expectations throughout the filing cycle.

Late Filing Without IRS Extension: What Happens

Timely filing of Form W-2 is a core requirement under IRS wage reporting regulations. Employers who fail to meet the January 31 deadline and do not submit a formal extension request may face escalating penalties. 

These penalties apply to all filers, including businesses that submit only a few returns. The IRS enforces these rules to maintain consistency in employee wage reporting, reduce income tax filing errors, and ensure employees receive accurate wage documentation on time.

Common Consequences of Late Filing

  • Filing up to 30 calendar days late results in a penalty of $60 per return, which applies even when the correct information is eventually submitted.

  • Filing between 31 days after the deadline and August 1 increases the penalty to $130 per return.

  • Filing after August 1 or failing to file altogether raises the penalty to $330 per return.

  • Delayed or missing filings can cause the IRS to issue Notice 972-CG, a formal communication outlining proposed penalties for noncompliance.

  • Employees who do not receive timely W-2 forms may experience delays in filing their individual tax returns or receiving their expected refunds.

  • Late W-2 data submission can disrupt Social Security Administration records, creating inconsistencies in employee earnings history.

Employers unable to meet the standard January 31 deadline may request an automatic 30-day extension using IRS Form 8809. The form must be filed on or before the original due date to be considered valid. Filing without an approved extension may result in full exposure to penalties, regardless of intent or previous compliance history.

Consistent review of internal payroll schedules and calendar reminders helps minimize filing oversights. Aligning internal deadlines with IRS expectations ensures smoother processing and protects employers from unnecessary penalties related to late reporting.

What to Do If You Get IRS Notice 972-CG

Purpose of IRS Notice 972-CG: The Internal Revenue Service issues Notice 972-CG to inform employers of proposed penalties for failing to file correct information returns, such as Form W-2, on time. The notice identifies each return in question, outlines the type of filing error, and details the monetary penalty associated with each issue. This correspondence is not a final assessment but serves as an opportunity for the employer to review the claims and respond with any applicable explanations or corrections.

Timeframe to Respond: Employers have 45 calendar days from the date listed on the notice to respond. For international filers, the response window extends to 60 days. Reviewing the records immediately after receiving the notice is essential, as extensions are not automatically granted. Waiting too long may result in automatic penalty assessment, even if the employer believes the notice contains inaccuracies.

What to Include in the Response: A formal written explanation should be submitted if the employer intends to dispute the proposed penalty. Supporting documentation must accompany this explanation and demonstrate that the filing issue resulted from reasonable cause rather than willful neglect. Examples of acceptable supporting materials include system error logs, correspondence with a payroll provider, or proof of filing attempts.

How to Submit the Response: The employer must send the reply to the IRS address listed on the notice. All responses should include the name and contact information of the person responsible for payroll reporting and any relevant control numbers referenced in the notice. Documentation should be organized and labeled clearly to help facilitate IRS review and decision-making.

Responding to Notice 972-CG promptly, completely, and professionally improves the employer’s chances of penalty reduction or complete abatement. A clear, fact-based explanation supported with accurate records allows the IRS to assess the employer’s compliance efforts and determine it more favorably.

How to Apply for a TCC and Access FIRE or IRIS

Understanding the Purpose of a TCC

A Transmitter Control Code (TCC) is a unique identifier assigned to filers who transmit information returns electronically through the IRS FIRE or IRIS systems. Without a valid TCC, employers cannot submit Forms W-2, 1099-NEC, or other applicable documents electronically. 

The code confirms authorization to access the system and whether the filer uses direct upload tools or an application-to-application (A2A) format is required. For tax year 2023 and beyond, obtaining a TCC has become mandatory for most employers, particularly those who meet the 10-return filing threshold.

Comparison of FIRE and IRIS Platforms

  • Primary Use
    • FIRE System: Designed for bulk filers and software developers
    • IRIS System: Best for small to mid-sized filers who want direct upload capability
  • Interface
    • FIRE System: Requires technical setup and adherence to IRS specifications
    • IRIS System: User-friendly, web-based portal
  • File Format
    • FIRE System: ASCII text only
    • IRIS System: XML uploads or online form entry
  • TCC Requirement
    • FIRE System: Requires a TCC
    • IRIS System: Requires a separate TCC
  • Secure Access
    • FIRE System: Password-protected login
    • IRIS System: ID.me verification with a locked padlock icon for added security
  • Applicants must use the IRS’s IR Application Portal, accessible through the agency’s official FIRE webpage. Access requires ID.me authentication, including a verified photo ID and multi-factor security procedures, such as a locked padlock icon in the browser address bar. Applicants must provide their employer identification number, legal business name, job title, and details for any authorized delegates.

    To resolve transmission or application issues, filers should communicate directly with IRS technical support or reference the last reviewed date on the system notice. All responses must include accurate subject lines, postmarked documents, and verified control totals. Late or incomplete applications may result in delayed access and failure to meet the extension of time request deadline.

    Completing the TCC application accurately prevents rejected filings and supports timely IRS compliance. With FIRE and IRIS increasingly used for IRS information return processing, timely preparation addresses technical barriers, enables secure system access, and promotes proper recordkeeping for the reporting year.

    Frequently Asked Questions

    What is the IRS calendar year deadline for filing Form W-2?

    The IRS requires employers to file Form W-2 with the Social Security Administration and provide employee copies no later than January 31 following the tax year. Meeting this deadline ensures accurate wage reporting and prevents processing delays. Employers should regularly check IRS publications labeled 'last reviewed or updated' to identify any year-specific changes for the upcoming filing cycle.

    When is the time to file electronically using the IRS e-file systems?

    Employers required to e-file must do so by January 31 for most wage and tax documents. This includes Form W-2 and related information returns filed through the IRS’s FIRE or IRIS systems. The time to file should align with the reporting year’s deadlines, and all preparers should confirm system availability beforehand. Delays caused by technical errors may not excuse late filing if no extension of time was granted.

    What is the purpose of a transmitter control code TCC, and who needs one?

    The IRS issues a transmitter control code (TCC) to authorize electronic filing through the FIRE or IRIS systems. Businesses, payroll service providers, and tax professionals must obtain a TCC to transmit returns electronically. A separate TCC is required for each platform, and the process includes multi-step identity verification. Without a valid TCC, employers cannot complete the e-filing process or meet submission requirements for Forms W-2, 1099, or others.

    Can I request an extension of time to file Form W-2?

    Yes, employers who anticipate missing the January 31 deadline may submit Form 8809 to request a 30-day extension of time. This request must be filed before the original due date. Late or improperly completed forms are typically denied. An approved extension provides more time to finalize payroll records, complete year-end reconciliations, and confirm totals. Extensions are not automatic and require careful planning to avoid missed filing windows.

    How does the 10-return rule affect e-file requirements for tax year 2023?

    For tax year 2023, employers filing 10 or more total information returns across all form types must e-file through an approved IRS system. This includes W-2s, 1099-NEC forms, and similar documents. The combined total of all submitted form types determines whether electronic filing is required, even when filed individually. Employers should verify their return count before submission. Failing to comply with e-filing rules without an approved waiver may lead to IRS penalties and increased scrutiny in future years.

    What happens if I receive a bill or notice after I already filed?

    If the IRS issues a bill or penalty notice after submitting a return, employers should confirm the postmark date and review the specific subject line and filing history. In some cases, returns may have been rejected without confirmation. To resolve the issue, employers may need to speak with IRS representatives or provide supporting evidence, such as confirmation receipts. Timely communication and accurate documentation improve the chances of a favorable resolution.

    How do I speak to the IRS about an IRIS or FIRE system access problem?

    Contact the IRS support team listed on the system access page to resolve technical issues related to FIRE or IRIS access. Representatives will verify the business's identity and may request additional authentication. Providing the correct control totals, account details, and references to the specific filing issue will help expedite support. Maintain communication records, including the internal case or reference number issued during the call.