Multi-State 1099 Filing Requirements: CF/SF Coverage and Direct-Filing Exceptions
During filing season, sending 1099s to the IRS is often only half the job payers need to complete. A payer with contractors in California and Oregon, or a firm filing for a dozen clients, can still owe state copies the federal filing never reaches. Whether it does depends on the form, any state tax withheld, and the amount reportable to each state. Knowing how many states take federal data is a start. It won't tell you which ones still want their own copy.
We went through 28 primary IRS, state-agency, and state-law documents, current as of October 5, 2026, counting each publication, webpage, and statute once. Publication 1220 (Rev. May 2026), which governs tax year 2025 returns filed in 2026, and Oregon DOR’s own notice put 31 states plus the District of Columbia in the Combined Federal/State Filing (CF/SF) Program for TY2025: 32 of 51 jurisdictions, or 62.7%. That's a count of jurisdictions in the program. It says nothing about how many businesses file in several states or how many returns skip a state submission. IRS Publication 1220; Oregon DOR
Oregon presented a challenge. Publication 5718 (Rev. January 2026) still lists it, Oregon says it doesn't participate, and the newer Publication 1220 (Rev. May 2026, for TY2025 returns) sides with Oregon so we left it out. We used the same rule throughout: when sources disagree, the newer, more specific one wins. Each state rule below carries the tax year its source covers. For most forms, TY2025 returns are filed in 2026 and TY2026 returns in 2027, though deadlines vary by form and state. The filing-path examples at the end use TY2025 rules and are hypothetical. They show how the rules stack up; they don't estimate filing volumes or cover every TY2026 requirement. IRS Publication 1220; IRS Publication 5718; Oregon DOR
CF/SF Participation by State: 2026 Research Snapshot
The participant list below comes from the May 2026 revision of Publication 1220 for tax year 2025 returns. The table covers every state and DC on the reconciled IRS participant list. Both 1099-NEC and 1099-MISC appear among the federally eligible CF/SF form types; state-specific conditions still apply. "Yes" means the jurisdiction is listed, which doesn't guarantee that forwarding satisfies every state requirement. "No" means no CF/SF filing path is listed; the jurisdiction may still have other reporting duties. IRS Publication 1220
The Multi-State CF/SF Participation Census: 2026
| Jurisdiction | Listed in IRS Publication 1220 as a TY2025 CF/SF participant | IRS CF/SF code |
|---|---|---|
| Alabama | Yes | 01 |
| Alaska | No | Not Listed |
| Arizona | Yes | 04 |
| Arkansas | Yes | 05 |
| California | Yes | 06 |
| Colorado | Yes | 07 |
| Connecticut | Yes | 08 |
| Delaware | Yes | 10 |
| District of Columbia | Yes | 11 |
| Florida | No | Not Listed |
| Georgia | Yes | 13 |
| Hawaii | Yes | 15 |
| Idaho | Yes | 16 |
| Illinois | No | Not Listed |
| Indiana | Yes | 18 |
| Iowa | No | Not Listed |
| Kansas | Yes | 20 |
| Kentucky | No | Not Listed |
| Louisiana | Yes | 22 |
| Maine | Yes | 23 |
| Maryland | Yes | 24 |
| Massachusetts | Yes | 25 |
| Michigan | Yes | 26 |
| Minnesota | Yes | 27 |
| Mississippi | Yes | 28 |
| Missouri | No | Not Listed |
| Montana | Yes | 30 |
| Nebraska | Yes | 31 |
| Nevada | No | Not Listed |
| New Hampshire | No | Not Listed |
| New Jersey | Yes | 34 |
| New Mexico | Yes | 35 |
| New York | No | Not Listed |
| North Carolina | Yes | 37 |
| North Dakota | Yes | 38 |
| Ohio | Yes | 39 |
| Oklahoma | Yes | 40 |
| Oregon | No | Not Listed |
| Pennsylvania | Yes | 42 |
| Rhode Island | Yes | 44 |
| South Carolina | Yes | 45 |
| South Dakota | No | Not Listed |
| Tennessee | No | Not Listed |
| Texas | No | Not Listed |
| Utah | No | Not Listed |
| Vermont | No | Not Listed |
| Virginia | No | Not Listed |
| Washington | No | Not Listed |
| West Virginia | No | Not Listed |
| Wisconsin | Yes | 55 |
| Wyoming | No | Not Listed |
The 32 listed jurisdictions make up 62.7% of the 51-jurisdiction research population, and 19 aren't listed. These are program-coverage counts. They don't count the states that require 1099-NEC or 1099-MISC reporting. DC is included in the jurisdiction total but not in the 31-state total. IRS Publication 1220
Oregon is a material exception to earlier lists. Publication 5718 (Rev. January 2026), which is superseded on this point, still lists Oregon, but Oregon DOR says its inclusion in an earlier federal publication was inadvertent and that required forms must be sent through iWire. The TY2025 participant list in Publication 1220 (Rev. May 2026) excludes Oregon. So we count Oregon as a nonparticipant and don't treat the outdated list as a current filing instruction. IRS Publication 5718; IRS Publication 1220; Oregon DOR
For businesses preparing 1099 forms, program availability is only one part of the submission plan. Section 12 of Publication 1220 (Rev. May 2026, for TY2025 returns) describes the IRS's role as forwarding qualifying records to participating states and tells issuers to verify each state's criteria, and some participating states require separate notification or direct reporting. IRS Publication 1220
Direct State 1099 Reporting: Selected Rules Reviewed in October 2026
Program membership and completed state reporting are two different things. These 15 jurisdiction examples show conditions that change the filing path. They aren't a complete state-by-state eligibility checklist or a representative sample for calculating a national direct-filing percentage, and each example stays subject to the form and tax-year limits in its agency guidance.
Payment eligibility is separate from the submission path. For tax years beginning after 2025, the federal reporting threshold for covered Form 1099-NEC payments generally increases from $600 to $2,000.
Backup withholding and other special reporting rules can still require reporting below the normal threshold. The federal threshold change doesn't set a state's reporting threshold or forwarding requirements on its own. Other payment categories have separate rules; our 1099 filing statistics report covers the broader federal context. IRS TY2026 instructions; IRS 2025 instructions
The Selected Direct State Reporting Conditions: October 2026 Review
| Jurisdiction | Forms covered by the example | When reporting is required | Effect on the filing path |
|---|---|---|---|
| California | 1099-NEC and 1099-MISC | California resident or part-year resident, or a California-source transaction, subject to the applicable form rules. | Under the applicable FTB rules, a qualifying CF/SF filing may avoid a duplicate copy when the federal and California-reportable amounts match; otherwise, a separate filing may be required. California FTB |
| Connecticut | 1099-NEC and 1099-MISC | Connecticut reporting criteria apply; distinguish forms with and without Connecticut withholding. | A separate submission to DRS is required when Connecticut withholding is reported; its CF/SF section directs these forms through myconneCT. CF/SF can satisfy the requirement without Connecticut withholding. Confirm DRS eligibility before relying on its general low-volume paper provision. Connecticut DRS |
| Delaware | 1099-NEC and 1099-MISC | Forms issued to Delaware residents, or to nonresidents for work performed in Delaware. | Submit directly to the Division of Revenue despite CF/SF participation. Delaware DOR |
| District of Columbia | Required 1099 information returns | Apply OTR's tax-year-specific reporting rules; the cited direct-filing notice concerns TY2025. | TY2025 only; confirm TY2026 instructions before filing. OTR requires a separate direct filing for TY2025 through MyTax.DC.gov, including approved CF/SF filers. DC OTR |
| Idaho | 1099-NEC and 1099-MISC | NEC issued for services performed in Idaho; MISC issued for transactions involving property located or used in Idaho. | Qualifying CF/SF reporting avoids a duplicate state copy. If the CF/SF records include Idaho withholding, file Form 967 separately. Idaho Tax Commission; Idaho filing guide |
| Kentucky | 1099-NEC and 1099-MISC | The cited TY2025 specifications require Form 1099 only when Kentucky tax is withheld. | File through the accepted Kentucky process. Paper copies of 1099s are not processed; the guide provides K-5 or accepted electronic-format options for smaller filers. Kentucky DOR |
| Maine | 1099-NEC and 1099-MISC, among listed forms | Section 5242 allows required information returns for payments of $600 or more to persons potentially subject to Maine income tax; apply the assessor's requirements and TY2025 specifications. | For filers covered by Maine's applicable electronic-filing requirement, the cited TY2025 specifications direct submission through the Maine Tax Portal rather than reliance on CF/SF. Do not treat this requirement as the complete rule for smaller filers. Maine statute; Maine Revenue Services |
| Massachusetts | 1099-NEC and 1099-MISC, among other forms | Annual reports of income taxable under Massachusetts Chapter 62. | File the annual report directly with DOR even if the transmitter participates in CF/SF. Massachusetts DOR |
| Michigan | 1099-NEC and 1099-MISC (other forms may apply) | 1099s issued to Michigan residents, regardless of where the issuer is located, where the work or transaction occurred, or whether withholding is shown. | Michigan participates in CF/SF, but as of our October 5, 2026 review it can’t receive 1099 copies submitted through IRIS. Form 1099-NEC must be filed directly with Michigan Treasury. Filers using IRIS for any 1099s required in Michigan must file 1099-NEC and 1099-MISC (and possibly other forms) directly with Michigan Treasury, and shouldn’t assume federal submission satisfies their Michigan obligation. Michigan Treasury |
| Minnesota | Any 1099 reporting Minnesota withholding | Minnesota income tax withholding is reported on the form. | Send directly to Minnesota even when participating in the federal/state combined program. Minnesota DOR |
| Missouri | 1099-NEC and 1099-MISC | Under the cited TY2025 guide, the same federal 1099 must be required, and Missouri-source payments must be $1,200 or more; apply the listed exceptions. Confirm the TY2026 guide before filing. | Separate Missouri filing is required. The state is not in CF/SF for TY2025; the guide permits electronic or alternative filing methods. Missouri DOR |
| New Mexico | 1099-NEC and 1099-MISC; special MISC rules | FYI-330 does not require NEC/MISC reporting of TRD-41409 withholding unrelated to pensions, annuities, or gambling. Oil-and-gas remitters have separate annual statement duties. | General NEC/MISC submission described above is voluntary. Required oil-and-gas reporting may use 1099-MISC, a pro forma, or RPD-41285; apply the guide's approved filing methods and timing rules. New Mexico TRD |
| North Carolina | 1099-NEC and 1099-MISC | TY2026 rule: File Forms 1099-NEC and 1099-MISC when North Carolina income tax withholding is reported. | Required statements must be filed directly with NCDOR. CF/SF does not satisfy the North Carolina filing requirement. Form NC-3 is required when the payer was required to withhold or voluntarily withheld North Carolina income tax; otherwise, certain information returns may be filed separately without Form NC-3.. North Carolina DOR |
| Ohio | 1099-NEC and 1099-MISC | TY2025 rule: the specifications require submission when Ohio individual or school-district income tax was withheld; no submission is required if neither was withheld. Confirm TY2026 specifications before filing. | The specifications direct covered electronic withholding filers to Ohio tax eServices' Upload Income Statement feature. Do not assume CF/SF membership removes that state upload. Ohio NEC specifications; Ohio MISC specifications |
| Oregon | Required 1099-NEC and 1099-MISC | Oregon includes both forms among its required information returns; apply its reporting rules. | Submit electronically through iWire. Oregon expressly says it does not participate in CF/SF. Oregon DOR |
This sampling shows that withholding isn’t a universal on/off switch for state reporting. Minnesota’s cited requirements include direct filing when Minnesota withholding is reported, while Delaware’s NEC/MISC requirement covers resident recipients and nonresidents performing work there. California separately identifies recipient residency and California-source transactions. A filing checklist that only asks whether state tax was withheld will miss these distinctions. Minnesota DOR; Delaware DOR; California FTB
Connecticut's guidance needs a method-level check on top of the forwarding decision. Its general section requires electronic filing for 25 or more listed information returns and allows paper for 24 or fewer, while its CF/SF section specifically directs withholding forms through myconneCT. Don't assume the general paper provision overrides that instruction in a particular withholding case; confirm the applicable method with DRS before filing. Connecticut DRS
Form type matters too. Michigan participates in CF/SF but, as of our October 5, 2026 review, isn’t receiving 1099 copies submitted through IRIS, and it requires 1099-NEC to be filed directly regardless. That agency-specific instruction takes precedence over Publication 1220’s TY2025 statement that both NEC and MISC are eligible CF/SF forms. Michigan Treasury; IRS Publication 1220
A state's own reporting threshold can also differ from the federal one. Missouri's TY2025 guide pairs a federal filing obligation with a $1,200 Missouri-source condition. Maine's statute and its electronic-filing specifications answer different questions: the authority to require payment reporting, and the required submission method for covered filers. New Mexico's guide also shows that withholding alone isn't a universal NEC/MISC filing trigger. These source-specific rules shouldn't be relabeled as a nationwide TY2026 threshold schedule. Missouri DOR; Maine statute; Maine Revenue Services; New Mexico TRD
Track submission paths separately from filing deadlines. A federal transmission, a state copy, and a state reconciliation are different tasks. Knowing which path applies doesn't tell you the due date or satisfy a separate reconciliation requirement.
State Electronic-Filing Triggers: Selected Rules Reviewed in October 2026
The ten jurisdiction examples below keep each agency's electronic-filing trigger and counting basis. They're a selected comparison rather than a nationwide census, and they shouldn't be read as ten interchangeable form-volume thresholds.
The Selected State E-Filing Triggers: October 2026 Review
| Jurisdiction | Published electronic-filing trigger | What is counted | Submission requirement |
|---|---|---|---|
| California | 10 or more information returns | Information returns submitted by the reporter. | SWIFT for direct FTB filings; CF/SF forwarding may remove the need for a duplicate FTB submission. California FTB |
| Michigan | 10 or more income record forms | Michigan income record forms, not only 1099-NECs. | Michigan Treasury Online (MTO), using the required file format. Michigan Treasury |
| Minnesota | More than 10 forms | W-2s plus 1099s combined. | e-Services; 10 or fewer forms may be submitted on paper under the cited state guidance. Minnesota DOR |
| Vermont | More than 10 forms; separate rule for multi-employer preparers | Total combined W-2s and 1099s. Payroll services and tax preparers filing for multiple employers must use myVTax regardless of that volume test. | myVTax; confirm the current specification year before filing. Vermont Tax Department |
| Kansas | 51 or more employees or payees | People covered by statements reporting withholding information; do not substitute a per-form-type count. | Kansas electronic withholding reporting, subject to the state's hardship provision. Kansas DOR |
| Nebraska | Over 50 forms for TY2026 | The state's TY2026 notice covers W-2, W-2G, 1099-MISC, 1099-NEC, and 1099-R. | Nebraska electronic filing; the notice concerns TY2026 forms filed in 2027. Nebraska DOR |
| New Jersey | Mandatory for required W-2s and 1099s | The cited mandate supplies no small-volume exclusion. | New Jersey's prescribed electronic reporting options. New Jersey Taxation |
| Iowa | Required for forms containing Iowa withholding | Issued W-2s and 1099s containing Iowa withholding. The cited page addresses TY2025; confirm TY2026 instructions before filing. | GovConnectIowa. Iowa DOR |
| Oregon | Required for applicable 1099s, including low-volume filings | Required Oregon information returns, including 1099-NEC and 1099-MISC. | iWire. Oregon's current guidance requires required 1099s to be filed electronically and traces this requirement to TY2017. Oregon DOR |
| Utah | Required for 1099s with Utah tax withheld | 1099s covered by Utah withholding and reconciliation rules. | Utah's electronic system; Publication 14 states that paper withholding forms will be rejected. Utah Tax Commission |
The thresholds describe standard filing rules. Exceptions aren't available in every jurisdiction, so where an agency offers a waiver process, confirm its requirements before using a different filing method. California, for example, directs filers to Form FTB 6274. California FTB
The difference between "10 or more" and "more than 10" matters. For the covered California direct-filing population, the cited rule starts at 10 information returns submitted by the reporter, while Minnesota allows paper copies for 10 or fewer combined W-2s and 1099s. Those state thresholds don't decide whether paper filing is allowed federally; federal electronic-filing requirements have to be checked separately. California FTB; Minnesota DOR; IRS TY2026 instructions
Kansas counts employees or payees covered by statements reporting withholding, while Nebraska's TY2026 notice refers to over 50 forms. Calling both "a 50-form rule" loses both the boundary and the counting basis. Vermont adds a separate requirement for payroll services and tax preparers submitting for multiple employers. Kansas DOR; Nebraska DOR; Vermont Tax Department
As a practical implication of these rules, not a measured result, an accounting firm's useful record goes beyond the number of 1099s in an imported file. It covers the applicable issuer, state, form type, withholding condition, and counting population. The thresholds above describe required submission methods and say nothing about the percentage of businesses that file electronically.
Hypothetical Direct-Reporting Path Examples: TY2025 Forms Filed in 2026
These examples hold the reporting footprint constant at California, Connecticut, and Oregon. Assume the payer has already established its TY2025 1099-NEC reporting obligations in all three jurisdictions and correctly submits the qualifying CF/SF records. Changing the conditions can change how many of these three jurisdictions require direct reporting, even though the payer’s state footprint stays the same. California FTB; Connecticut DRS; Oregon DOR
The Hypothetical Three-Jurisdiction Filing Path Examples: 2026
| Scenario | Jurisdictions with established obligations | Eligible for CF/SF Forwarding | Jurisdictions requiring direct reporting | Direct-reporting jurisdiction count |
|---|---|---|---|---|
| A. Matching federal/state amounts; no Connecticut withholding | California, Connecticut, Oregon | California and Connecticut, under the stated qualifying conditions | Oregon | 1 |
| B. Add Connecticut withholding | California, Connecticut, Oregon | California, under the stated qualifying conditions | Connecticut and Oregon | 2 |
| C. Also report a different California amount | California, Connecticut, Oregon | None | California, Connecticut, and Oregon | 3 |
In Scenario A, CF/SF forwarding covers the California and Connecticut reporting described here, and Oregon requires direct iWire reporting.Adding Connecticut withholding creates a second direct-reporting jurisdiction. If the California amount then differs from the federal amount, California's instruction requires a separate return, which brings the direct-reporting count to three. These counts are calculated from the stated assumptions and agency rules. They don't come from Yearli customer data or an industry survey. California FTB; Connecticut DRS; Oregon DOR
A direct-reporting jurisdiction count isn't a count of forms, recipients, files, portal sessions, or hours worked. A single transmission may contain multiple payers or records, depending on the agency and filing method, and agencies may require additional reconciliation work. When the same payment is reportable to more than one state, IRS program instructions also require an appropriate allocation instead of reporting the full payment to every state. IRS Publication 1220; IRS Publication 5718
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Sources
- Yearli, Grand Rapids, Michigan. Multi-State 1099 Filing Statistics Research Compilation, October 2026. Original jurisdiction census and illustrative calculations presented in this report, compiled from the primary documents below. No separate survey of filer behavior was conducted.
- IRS Publication 1220, Rev. May 2026, Section 12 and Table 1. Reviewed October 5, 2026. https://www.irs.gov/pub/irs-pdf/p1220.pdf
- IRS Publication 5718, Rev. January 2026, Section 9 and Table 9-1. Superseded on Oregon's CF/SF status; cited for comparison. Reviewed October 5, 2026. https://www.irs.gov/pub/irs-pdf/p5718.pdf
- IRS Instructions for Forms 1099-MISC and 1099-NEC, April 2025 revision. Reviewed October 5, 2026. https://www.irs.gov/pub/irs-prior/i1099mec--2025.pdf
- IRS Instructions for Forms 1099-MISC and 1099-NEC, current online edition as available on October 5, 2026. https://www.irs.gov/instructions/i1099mec
- California FTB, Guidance for Reporting Information Returns. Reviewed October 5, 2026. https://www.ftb.ca.gov/file/business/information-returns.html
- Connecticut DRS, Filing Requirements: 1099 and W-2G Electronic Filing. Reviewed October 5, 2026. https://portal.ct.gov/drs/withholding-taxes/1099s-electronic-filing-req/filing-requirements
- Delaware Division of Revenue, W-2 and 1099 Form FAQs. Reviewed October 5, 2026. https://revenue.delaware.gov/frequently-asked-questions/w-2-and-1099-form-faqs/
- DC Office of Tax and Revenue, Bulk Filing, TY2025 instructions. Reviewed October 5, 2026. https://otr.cfo.dc.gov/publication/bulk-filing-sales-and-use-withholding-and-information-returns
- Michigan Treasury, Income Record Form Remittance Guide. Reviewed October 5, 2026. https://www.michigan.gov/taxes/business-taxes/incomestatement/income-record-form-remittance-guide
- Minnesota DOR, Withholding Fact Sheet 2a: Submitting Form 1099 Information. Reviewed October 5, 2026. https://www.revenue.state.mn.us/submitting-form-1099-information
- Oregon DOR, iWire: W2 and 1099 Reporting. Reviewed October 5, 2026. https://www.oregon.gov/dor/programs/businesses/pages/iwire.aspx
- Kansas DOR, W-2 and 1099 Frequently Asked Questions. Reviewed October 5, 2026. https://www.ksrevenue.gov/faqs-w2.html
- Massachusetts DOR, Form 1099 Filing Requirements. Reviewed October 5, 2026. https://www.mass.gov/info-details/form-1099-filing-requirements
- Iowa DOR, File a W-2 or 1099. Reviewed October 5, 2026. https://revenue.iowa.gov/i-need/file-w-2-or-1099
- Nebraska DOR, Income Tax Withholding Forms: TY2026 Reminders. Reviewed October 5, 2026. https://revenue.nebraska.gov/about/forms/income-tax-withholding-forms
- Utah State Tax Commission, Publication 14. Reviewed October 5, 2026. https://tax.utah.gov/form-pubs/pub-14
- Vermont Department of Taxes, 1099 Information E-filing Specifications. Reviewed October 5, 2026. https://tax.vermont.gov/business/withholding/1099-specifications
- New Jersey Division of Taxation, Electronic Filing Mandate for All W-2s and 1099s. Reviewed October 5, 2026. https://www.nj.gov/treasury/taxation/git/efilemand.shtml
- Idaho State Tax Commission, Types of Withholding Forms. Reviewed October 5, 2026. https://tax.idaho.gov/taxes/income-tax/withholding/forms
- Idaho Guide to Income Tax Withholding, information-return filing instructions, October 2025. Reviewed October 5, 2026. https://tax.idaho.gov/document-mngr/pubs_EPB00667/
- Kentucky DOR, 2025 Specifications for Electronic Submission of 1099 and W-2G Information. Reviewed October 5, 2026. https://revenue.ky.gov/Forms/2025 Specifications for Electronic Submission of 1099B, 1099DIV, 1099G, 1099INT, 1099K, 1099MISC, 1099NEC, 1099OID, 1099R and W2G Tax Information on CD or MyTaxes.ky.gov.pdf
- Maine Revenue Services, 2025 Form 1099 and W-2G Electronic Filing Specifications, December 2025. Reviewed October 5, 2026. https://www.maine.gov/revenue/sites/maine.gov.revenue/files/inline-files/2025 FINAL 1099 W-2G Specifications_0.pdf
- Maine Revised Statutes, Title 36, Section 5242: Information Returns. Reviewed October 5, 2026. https://legislature.maine.gov/statutes/36/title36sec5242.html
- Missouri DOR, 2025 1099 Filing Guidelines. Reviewed October 5, 2026. https://dor.mo.gov/taxation/business/tax-types/withholding/documents/Missouri1099FilingGuidelines.pdf
- New Mexico TRD, FYI-330: Income and Withholding Information Returns and Filing Methods, December 2025. Reviewed October 5, 2026. https://realfile.tax.newmexico.gov/FYI-330.pdf
- Ohio Department of Taxation, 2025 Form 1099-NEC Upload Specifications. Reviewed October 5, 2026. https://dam.assets.ohio.gov/image/upload/tax.ohio.gov/employer_withholding/2025-2026 NYP Updates/2025_1099NEC_Specs_V1.pdf
- Ohio Department of Taxation, 2025 Form 1099-MISC Upload Specifications. Reviewed October 5, 2026. https://dam.assets.ohio.gov/image/upload/tax.ohio.gov/employer_withholding/2025-2026 NYP Updates/2025_1099MISC_Specs_V1.pdf
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