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IRS Unveils 2026 Draft Form W-9—Key Changes & Deadlines Every Taxpayer Should Know

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The U.S. Internal Revenue Service has quietly released a draft of Form W-9 dated “Rev. January 2026,” and the early look signals two compliance shake-ups every payer, platform and freelancer should know about. 1. Digital-asset broker exemption becomes official • A brand-new checkbox in Part II lets “U.S. digital asset brokers (other than registered investment advisers)” certify they are exempt from information reporting under Reg. §1.6045-1(g)(4)(i)(A)(1). • The form also adds Exempt Payee Code 14 to cover these crypto brokers through the 2026 tax year, aligning W-9 with the forthcoming Form 1099-DA reporting framework. • Why it matters: exchanges, wallet providers and any marketplace handling crypto must update substitute W-9s and onboarding flows or risk backup-withholding errors and costly B-Notices. 2. TIN rules tightened for sole proprietors and disregarded entities • The draft explicitly states: “Do not report the employer identification number (EIN) of a sole proprietorship or disregarded entity.” Instead, a sole proprietor must supply an SSN, and a disregarded entity must give the owner’s TIN. • Any vendor that previously furnished an EIN on Line 1 will now trigger a “change in circumstance,” forcing re-papering and validation checks. Firms should run proactive data sweeps to avoid mismatch penalties. Key takeaways for finance, procurement and gig-economy platforms • Retrofit digital onboarding journeys. Add the new checkbox, store Exempt Payee Code 14, and build logic that suppresses crypto-related backup withholding only when the box is ticked. • Refresh TIN-matching controls. IRS name/TIN mismatch letters (CP2100) and B-Notice campaigns rise when sole proprietors use EINs. Scrub your payee files now to quarantine at-risk records. • Communicate early with suppliers and creators. A short campaign explaining “why we need your SSN, not your EIN” minimizes friction and delays in January 2026. Industry reaction Reg-tech analysts note that the IRS moved from the sizable March 2024 overhaul to this new draft in less than two years, underscoring how fast tax documentation is evolving for digital assets. Compliance vendors are already updating e-signature templates, while some payment processors plan API flags to auto-reject sole-proprietor EINs. What’s next The draft will likely finalize by late 2025, giving businesses one peak filing season to prepare. Monitor IRS bulletins for any tweaks, especially if the definition of “digital asset broker” broadens or the grace period for Code 14 shortens. Bottom line Form W-9 may look familiar, but the 2026 revision is a wake-up call: crypto reporting is mainstream, and sloppy TIN collection is no longer tolerated. Updating forms, systems and supplier education now means fewer penalties—and fewer headaches—when the final W-9 hits in January 2026.

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