When a payment crosses the reporting threshold
The threshold applies per vendor, per calendar year, and it measures the total paid across the year rather than any single check. For payments made in 2026 and later, the reporting threshold under IRC Section 6041(a) is $2,000, and the amount is adjusted for inflation in future years. A property manager paid $250 a month crosses it. A plumber paid once for a $900 repair does not.
This applies regardless of plan type. The obligation follows the payer, and the payer is your plan entity.
Which payments count
Only payments for services made in the course of the plan's business are reportable on Form 1099-NEC. Goods and materials are not, so a $3,500 appliance purchase falls outside the rule while $3,500 paid to the contractor who installed it does not.
Payments made with the plan's debit card, or through a third-party payment network, are also excluded. A debit card is a payment card under IRC Section 6050W, so the settlement entity reports the transaction on Form 1099-K and the payer does not report it again. Rent paid to a property owner and gross proceeds paid to an attorney follow different rules and belong on Form 1099-MISC.
Collect the W-9 before you pay
Ask every new vendor to complete IRS Form W-9 before the first payment goes out. The W-9 gives you the legal name, business name, taxpayer identification number, and entity classification you need to file accurately, and it tells you whether the vendor is exempt from reporting at all.
Chasing a taxpayer identification number in January, after the work is finished and the vendor has moved on, is how filings get missed.
How and when to file
File Form 1099-NEC with the IRS and furnish a copy to the vendor. Both copies are due January 31 following the calendar year in which the payments were made, and unlike some other information returns, the IRS copy has no automatic extension.
The payer is your plan entity. Use the EIN of the LLC, Trust, or Solo 401(k), never your personal Social Security number. Filing under a personal identifier reports the payment as coming from you rather than the plan, which creates a record you will have to correct.
Frequently Asked Questions
What if I paid a vendor less than the threshold for the year?
No filing is required below the threshold. Retain the payment records anyway, since they support the plan's expense documentation whether or not a form is filed.
Does this apply to payments made to corporations?
Payments to C corporations and S corporations are generally exempt. Payments to individuals, sole proprietors, partnerships, and most LLCs are not. Attorney fees are the common exception, reportable even when the law firm is incorporated. When you are unsure, the W-9 tells you how the vendor is classified.
What if I missed a filing?
File as soon as you identify the gap. Penalties scale with how late the form is, so correcting it immediately costs less than waiting for IRS contact. Have your CPA review any unfiled obligations from a prior year before you submit them.