# Subcontractor W-9 and 1099-NEC: a GC checklist

> Collect a W-9 before the first payment, match the name and TIN, know when backup withholding applies, and file 1099-NEC at the $2,000 threshold by January 31.

Collect a signed Form W-9 from every subcontractor before the first payment, check the name and taxpayer identification number (TIN), and file Form 1099-NEC by January 31 for each one you paid $2,000 or more for services during the year. The $2,000 threshold applies to payments made after December 31, 2025; before that it was $600. Payments to corporations are generally not reported, but attorneys' fees are.

## Why collect the W-9 before the first payment?

The W-9 gives you the subcontractor's legal name, federal tax classification, and TIN. You need all three to decide whether a 1099-NEC is required and to file it. The IRS says a properly completed and signed W-9 can be relied on to avoid backup withholding.

If a payee does not give you a TIN, you must backup withhold 24% of reportable payments. For nonemployee compensation this applies right away, even if the payee wrote Applied For: the 60-day grace period covers only interest, dividends, and certain readily tradable instruments.

You keep the W-9 in your files; it is not sent to the IRS. The current revision is dated March 2024.

## What should you check on the W-9?

1. **Line 1 name.** For a sole proprietor or a single-member LLC that is a disregarded entity, line 1 is the owner's name and the business name goes on line 2. The TIN must match the line 1 name.
2. **Line 3a classification.** Individual or sole proprietor, partnership, C corporation, S corporation, or LLC with its tax classification.
3. **Line 4 exemptions.** An exempt payee code, if entered, should fit the entity. Individuals and sole proprietors are generally not exempt.
4. **TIN, signature, and date.** An SSN or EIN in the right format, signed by the payee.
5. **Consistency.** The legal name should match the subcontract, the certificate of insurance, and the license.

## How does IRS TIN Matching work?

The IRS offers free online TIN Matching through e-Services to payers who file information returns subject to backup withholding, including Form 1099-NEC. You enter a name and TIN, and it tells you whether the combination matches IRS records. Interactive matching checks up to 25 at a time; bulk matching takes a file of up to 100,000.

Matching before you file lowers the chance of a CP2100 or CP2100A notice, which the IRS sends when a name and TIN on a filed return do not match. If one arrives, follow IRS Publication 1281. It can require you to start backup withholding on that subcontractor.

## Which subcontractors get a 1099-NEC?

The test is payments for services, in the course of your business, to someone who is not your employee, totaling $2,000 or more in the year.

| Payee | 1099-NEC at $2,000 or more? |
| --- | --- |
| Individual or sole proprietor | Yes |
| Single-member LLC treated as a disregarded entity | Yes, under the owner's name and TIN |
| Partnership, or LLC taxed as a partnership | Yes |
| C or S corporation, or LLC taxed as one | Generally no |
| Law firm, even if incorporated | Yes, for attorneys' fees |
| Supplier paid for materials only | No, merchandise is not reported |

Parts and materials go in box 1 when supplying them was incidental to the service, such as a repair that includes parts. Payments made by credit card or through a third-party payment network are reported by the payment settlement entity on Form 1099-K, not by you on a 1099-NEC.

## When is the 1099-NEC due?

Furnish the recipient's copy and file with the IRS by January 31, or the next business day if that falls on a weekend or legal holiday. For payments made in 2026, January 31, 2027 is a Sunday, so the deadline is Monday, February 1, 2027.

If you file 10 or more information returns in total for the year, counting Forms W-2 and all 1099 types together, you must file electronically. The IRS IRIS Taxpayer Portal lets you file 1099s online at no cost. The $2,000 threshold may be adjusted for inflation starting in 2027, so check IRS.gov each year.

## A year-end checklist

1. Run a payments report by vendor for the year.
2. Flag every non-corporate vendor, and every law firm, paid $2,000 or more for services.
3. Confirm a current W-9 is on file for each one, and request any that are missing.
4. TIN match the list if you are enrolled.
5. File and furnish by the deadline, and keep copies.

## Keep tax and insurance names in sync

The W-9 name should match the named insured on the certificate of insurance; otherwise you may be paying one entity while another is insured. See [certificate of insurance red flags](https://complysub.agntwrk.com/guides/certificate-of-insurance-red-flags) and [subcontractor prequalification](https://complysub.agntwrk.com/guides/subcontractor-prequalification) for what else to collect up front.

This is general information, not tax advice. Ask a tax professional about your situation.

## Where ComplySub fits

Subcontractors can keep a W-9 in their ComplySub compliance packet next to their certificate of insurance and license, so a general contractor gets all three from one link. ComplySub stores the W-9. It does not match TINs, withhold, or file 1099s.

[Try ComplySub free](https://complysub.agntwrk.com/login)

_This guide is general information, not legal or insurance advice. Insurance and licensing rules vary by state, carrier, and contract; confirm what applies to you with your insurance professional, attorney, or licensing board._