TL;DR
The One Big Beautiful Bill Act (OBBBA, H.R. 1, 119th Congress) was signed into law on 4 July 2025 as Public Law 119-21. For tax year 2026, the threshold for Form 1099-NEC and the equivalent boxes on Form 1099-MISC rose from $600 to $2,000. Inflation adjustment begins in 2027. The 1099-K threshold reverted to $20,000 and 200 transactions, repealing the temporary $600 threshold set by the American Rescue Plan Act of 2021. Several states retain their own thresholds at $600. Small businesses still need to collect W-9 forms from every contractor and follow backup withholding rules. The change reduces the number of 1099 forms filed but does not eliminate recordkeeping obligations.
What OBBBA changed
OBBBA (H.R. 1, 119th Congress) is a reconciliation bill that combined tax, spending, and border policy. The tax provisions include several changes that affect small businesses paying contractors.
Form 1099-NEC and 1099-MISC threshold change. The reporting threshold for nonemployee compensation rises from $600 to $2,000 in aggregate annual payments to a single payee, effective for payments made in calendar year 2026 and later. The threshold will be inflation-adjusted starting 2027.
Form 1099-K threshold revert. The 1099-K threshold reverts to $20,000 and 200 transactions, the pre-American Rescue Plan Act threshold. The $600 threshold for 1099-K had been temporarily delayed and partially implemented by the IRS. OBBBA permanently repealed the $600 threshold for 1099-K.
Backup withholding alignment. Backup withholding on payment card and third-party network transactions now aligns with the new 1099-K threshold.
The non-tax provisions of OBBBA (border policy, defence, healthcare) are outside scope for this guide.
Why the $600 threshold was raised
The $600 threshold dated to 1954. It was not indexed for inflation. By 2025, $600 in 2025 dollars purchased substantially less than $600 in 1954 dollars, and the threshold captured payments that were no longer economically meaningful.
Sponsors of OBBBA cited:
- Small businesses filing 1099s for payments that approximated single days of legal or accounting fees
- Administrative burden on the IRS in processing low-dollar 1099s
- High noncompliance rate at low dollar amounts
The new $2,000 threshold is broadly consistent with where the $600 threshold would sit if it had been indexed for inflation since 1954.
Timeline of changes
| Date | Event |
|---|---|
| 1 July 2025 | Senate passed the bill 51-50 |
| 3 July 2025 | House passed the bill 218-214 |
| 4 July 2025 | President Trump signed it into law as Public Law 119-21 |
| 1 January 2026 | $2,000 threshold takes effect for payments in tax year 2026 |
| 31 January 2027 | First 1099-NEC forms under the new threshold are due |
| 1 January 2027 | Inflation adjustment to the $2,000 threshold begins |
What does not change
Several important elements of the 1099 regime are unchanged.
Filing deadlines. Form 1099-NEC remains due 31 January of the year following payment. Form 1099-MISC is due 28 February (paper) or 31 March (electronic). Form 1099-K is due 31 March (electronic).
Electronic filing threshold. Under Treasury Regulation 1.6011-2, any filer required to file 10 or more information returns in aggregate must file electronically. This threshold did not change.
W-9 collection. Form W-9 collection is unchanged. Businesses should still collect W-9 from every contractor at engagement.
Backup withholding rules. The 24% backup withholding rate continues to apply when a payee fails to provide a TIN, provides an incorrect TIN, or is notified by the IRS of underreporting. The threshold for triggering backup withholding aligns with the new reporting thresholds.
Recordkeeping. Records supporting payments and information returns should be retained at least 4 years from the due date of the return, per IRC 6001.
State filing requirements. State reporting thresholds are independent of federal. Several states still require state-level reporting at $600.
State-by-state variations
OBBBA changes only the federal threshold. State income tax reporting is governed by state law. Major variations as of 2026:
| State | Approach |
|---|---|
| California | Follows federal threshold |
| New York | Follows federal threshold |
| Texas | No state income tax |
| Massachusetts | Requires reporting on payments above $600 if a Massachusetts-source connection exists |
| Vermont | Requires combined federal/state filing program with potentially different state threshold |
| Connecticut | State-specific thresholds in some categories |
| Maryland | State-specific reporting requirements |
| Pennsylvania | Specific thresholds for 1099-MISC for state purposes |
A small business that previously filed federal and state 1099s based on the $600 federal threshold may now need to track state thresholds separately. A payment of $1,200 may not require a federal 1099-NEC but may require a state report.
Practical impact by business size
The impact differs based on the size of the business.
Solo founders and very small businesses (< 10 contractors)
Most impact. Many payments to occasional contractors (a one-time logo design, a single legal consult) fall below $2,000 and no longer require 1099-NEC.
Practical change: fewer year-end 1099 filings. Continue collecting W-9 from every contractor regardless. Maintain payment records.
Small businesses (10 to 100 contractors)
Moderate impact. Aggregate contractor spend often exceeds $2,000 per individual contractor, especially for ongoing work. 1099-NEC remains required for most ongoing contractor engagements.
Practical change: more careful tracking of which contractors crossed $2,000 in the year. Ongoing contractors almost always cross. Occasional contractors may not.
Medium businesses (100 to 1,000 contractors)
Lower impact on filing volume because most contractor relationships are above the threshold. Still affects edge cases.
Practical change: minimal. Maintain standard W-9 and 1099-NEC workflow.
What happens with US tax for foreign contractors
OBBBA changed 1099 thresholds for US persons. Forms applicable to foreign persons did not change.
For payments to foreign contractors (non-resident aliens or foreign entities):
- Form W-8BEN or W-8BEN-E collection remains required
- Form 1042-S (Foreign Person’s U.S. Source Income Subject to Withholding) deadline remains 15 March of the year following payment
- Withholding rates under Chapter 3 of the Internal Revenue Code remain unchanged
- The 1099 threshold change is irrelevant for foreign payees because 1099 forms do not apply to non-US persons
US companies paying global contractors face two parallel regimes: 1099 for US persons (now $2,000 threshold) and 1042-S for foreign persons (no equivalent threshold, withholding requirements apply on US-source income).
Omnivoo Contract Management collects the appropriate tax form at onboarding (W-9 for US persons, W-8BEN for foreign individuals, W-8BEN-E for foreign entities) and maintains the records required for year-end reporting.
Comparing 1099-NEC vs 1099-MISC vs 1099-K
These three forms cover different payment types and have different thresholds and rules under the new regime.
| Form | Covers | Threshold (2026+) | Filing deadline |
|---|---|---|---|
| 1099-NEC | Non-employee compensation (most contractor payments) | $2,000 | 31 January |
| 1099-MISC | Rents, royalties, prizes, attorney fees, other specific payments | $2,000 for most boxes (some specific exceptions retain other thresholds) | 28 February (paper), 31 March (electronic) |
| 1099-K | Payment card and third-party network transactions | $20,000 AND 200 transactions | 31 March (electronic) |
Contractor payments through bank ACH or check are reported on 1099-NEC. Contractor payments through a third-party network such as PayPal, Venmo for business, Stripe, or similar are reported on 1099-K by the network. A single contractor receiving payments through a payment network may receive both a 1099-NEC from the business client (if the threshold is met) and a 1099-K from the network (if its threshold is met). The IRS reconciles these.
What small businesses should actually do
Practical action items based on the change.
1. Update W-9 collection for 2026 onboarding. Collect W-9 at engagement regardless of expected payment volume. The threshold change does not change W-9 obligations and does not reduce the need to verify TIN.
2. Maintain payment records. Track payments to each contractor against the $2,000 threshold. When a contractor crosses $2,000 in aggregate during the year, mark them for 1099-NEC at year-end.
3. Audit state reporting requirements. For each state with contractor activity, confirm the state’s 1099 reporting threshold. Several states still require reporting at $600.
4. Update contractor agreements. Most contractor agreements do not need updating for the threshold change. The threshold affects information reporting, not contracting law. However, agreements should still include W-9 collection and the contractor’s commitment to provide TIN on request.
5. Apply backup withholding consistently. If a contractor fails to provide a TIN or provides an incorrect TIN, withhold 24% from the payment. This is unchanged.
How Omnivoo Contract Management helps
Omnivoo Contract Management handles the contractor onboarding and tax document collection that 1099 reporting depends on. For each contractor:
- W-9 collection (US persons) or W-8BEN / W-8BEN-E (foreign persons) at onboarding
- TIN matching against IRS records where available
- Payment tracking by contractor for year-end aggregation
- 1099-NEC data export when contractors cross the $2,000 threshold
The product does not file 1099-NEC directly on the customer’s behalf. The data is provided in a format compatible with standard tax filing services.
Pricing is a flat $49 per finalized contract. Transaction fees pass through at cost. See pricing.
For small businesses paying global contractors, the threshold change reduces some federal filing burden but does not eliminate the recordkeeping discipline that proper contractor management requires. Talk to our team about year-end 1099 readiness for your contractor mix. Get in touch.