1099 vendor W-9 collection works best as a fall project, not a January one. Pull every vendor paid from the general ledger in November, drop the ones that need no 1099, request a W-9 from each vendor still missing one, follow up twice in December, and freeze the list in mid-January so 2026 forms go out by January 31.
Building the 1099 vendor list from the general ledger
The 1099 vendor list is the set of payees a client may have to report on Form 1099-NEC or 1099-MISC for the year. Build it from the general ledger, not from memory or the vendor master file, because the ledger shows who was actually paid, how much, and from which account. Start with the expense accounts where contractor payments land.
Pull a year-to-date vendor report in early November with payee, account, total paid and payment method. The accounts worth pulling usually include:
- Contract labor and subcontractors
- Professional fees, including legal and accounting
- Repairs and maintenance
- Rent, for a client that rents from an individual or partnership
- Commissions
- Any "miscellaneous" or "other expense" account, which tends to hide one-off contractors
Then add payees the expense report misses. A contractor paid by check from a balance sheet account, such as a construction-in-progress or fixed asset account, never shows up in an expense report. Scan the check register and the bank transactions for payees not on the list.
Merge duplicates as you go. "J. Ruiz", "Javier Ruiz" and "Ruiz Handyman" may be one payee with three spellings, and the total for the three together decides whether a 1099 is due. A list sorted by payee name and amount makes those easier to spot.
For tax year 2026, the threshold changed. The Instructions for Forms 1099-MISC and 1099-NEC (Rev. December 2026) say nonemployee compensation goes in Box 1a of Form 1099-NEC, and the reporting threshold increased to $2,000 for tax years beginning after 2025, with possible inflation adjustment from calendar year 2027. Set the list's cutoff to match the year being filed.
Which form each kind of payment belongs on has its own post. Read what belongs on a 1099-NEC and what belongs on a 1099-MISC for rent, attorney fees and the split between the two forms. For the ledger and trial balance reports this list starts from, see the financial statements and ledgers category.
Collect a W-9 before paying a contractor
To collect a W-9 before paying a contractor is to make the form a condition of the first payment, so the TIN is on file the day money goes out. This one habit removes most of the January scramble: a vendor who wants to be paid answers faster than one paid months ago.
The IRS rules point the same way. IRS Publication 1281 (Rev. 12-2023) says that for missing TINs the payer must make the initial solicitation when the payee opens the account or when the transaction occurs. It also says that if the payee does not provide a TIN when first asked, the payer must begin backup withholding. A W-9 collected at setup satisfies the first request and avoids the withholding question entirely.
Turn this into a rule the client follows:
- No new vendor is added to the payables system without a W-9 or a note explaining why none is needed.
- The W-9 is checked for a complete line 1, a line 3a box and a nine-digit TIN before the first payment.
- The form goes to the firm, which logs it in the client's W-9 tracker.
The tracker itself, with its columns and statuses, is described in a W-9 collection workflow for bookkeeping clients. That post also covers what the form asks for and which fields are easy to misread.
Clients push back on this rule when a contractor is needed urgently. The fallback is to send the W-9 request with the purchase order and hold the payment, not the work, until the form arrives.
Which vendors on the 1099 list need no W-9 follow-up?
Some vendors on the 1099 list need no W-9 follow-up because no Form 1099-NEC will be filed for them. The three common groups are corporations, vendors paid only by credit or debit card, and vendors paid less than the reporting threshold for the year. Each group has exceptions, so check before you cross a vendor off.
Corporations. The Instructions for Forms 1099-MISC and 1099-NEC say payments to a C or S corporation, including an LLC taxed as one, are generally exempt from reporting. Attorney fees are an exception and stay reportable. The catch is knowing that a vendor is a corporation. Publication 1281 says a payer cannot treat a payee as exempt just because "Company" or "Co." is in its name, and lists a W-9 with an EIN and a statement that the payee is a domestic corporation as one way to know. So a corporation still needs a W-9 on file; it just does not need a 1099 chase in January.
Card-paid vendors. The same instructions say payments made by credit card or payment card, and certain third-party network transactions, are reported on Form 1099-K by the payment settlement entity, not on Form 1099-NEC. A vendor paid only by card can come off the 1099-NEC list. A vendor paid partly by card and partly by check stays on it for the check amounts.
Payments below the threshold. A vendor paid less than $2,000 of nonemployee compensation in tax year 2026 does not need a 1099-NEC under the new threshold in the Instructions for Forms 1099-MISC and 1099-NEC. The exception: the same instructions say to file Form 1099-NEC for each person subject to backup withholding, regardless of the amount. A small vendor who never sent a W-9 and was withheld on still gets a form.
Mark each removed vendor with the reason in the tracker, such as "corporation, W-9 on file" or "card only". When a reviewer asks why a vendor with $14,000 in payments has no 1099, the answer is already there.
A 1099 vendor W-9 collection calendar from November to January
A 1099 vendor W-9 collection calendar spreads the work across the three months before the deadline so that January is review and filing, not chasing. The dates below are an example for one fictional bookkeeping client, Fernwood Landscaping, for tax year 2026. Adjust them to the firm's season and the client's volume.
| Example date | Action |
|---|---|
| Nov 3 | Pull the year-to-date vendor report from the general ledger. Merge duplicate payees. |
| Nov 7 | Remove corporations with W-9s on file, card-only vendors and vendors clearly below $2,000. Record the reason for each. |
| Nov 10 | Send W-9 requests to every remaining vendor without a usable form, with one place to return it. |
| Dec 1 | First follow-up to vendors who have not replied. Ask the client for a phone number or other contact for each. |
| Dec 15 | Second follow-up. Flag vendors still silent for the client to contact directly. |
| Dec 31 | For vendors whose accounts opened before December, the date by which Publication 1281 says the first annual solicitation for a missing TIN must be made. |
| Jan 6 | Pull December payments and add any new vendors or vendors who crossed the threshold. |
| Jan 13 | Freeze the vendor list. Review TINs on returned W-9s for format errors. |
| Jan 20 | Prepare 1099-NEC and 1099-MISC drafts for client review. |
| Jan 31 | Furnish recipient copies and file with the IRS. In 2027 this date falls on a Sunday. |
The deadline comes from the Instructions for Forms 1099-MISC and 1099-NEC, which say Form 1099-NEC must be furnished to recipients and filed with the IRS by January 31. The IRS General Instructions for Certain Information Returns (2025) add that when a due date falls on a Saturday, Sunday or legal holiday, the return is on time if filed by the next business day. The same general instructions say a filer with 10 or more information returns in total for the year must file electronically.
The December 31 line matters because of IRS Publication 1281. It says that, to avoid a penalty for filing a return with a missing TIN, the payer must make a first annual solicitation by December 31 of the year the account was opened, or by January 31 of the next year for accounts opened in December. A December follow-up with a fresh W-9 attached does that job, so keep a copy and a date.
Keying the returned W-9s and the ledger totals into the 1099 software is the step most firms still do by hand. The post on tax data entry automation looks at which parts of that entry can be read from the source documents instead of typed.
Schema CPA can help on the intake side: W-9s the client forwards through its upload link are read, filed with that client, and given a TIN pattern check, so the January 13 review starts from a list of malformed numbers. The client tracker demo shows how received and missing items are listed per client.
Can you file 1099s for contractors without a W-9?
Filing 1099s for contractors without a W-9 is allowed and is often required: a missing TIN does not cancel the duty to file. The payer files the 1099 with the TIN box blank. The consequences are backup withholding on payments, IRS notices listing the missing TIN, and possible penalties unless the payer can show it asked properly.
The IRS General Instructions for Certain Information Returns (2025) say that if the recipient does not provide a TIN, leave the box for the recipient's TIN blank, and that backup withholding may apply. IRS Publication 1281 adds that a payer generally must obtain a TIN even for a one-time transaction, and that after filing, the IRS may send a CP2100 or CP2100A notice listing missing TINs.
When that notice lists a missing TIN, Publication 1281 says the payer does not send a "B" notice. It must begin backup withholding if it has not already, make the annual solicitations Publication 1281 requires, and report amounts withheld on Form 945. Publication 1281 points to Publication 1586 for removing or reducing penalties because of reasonable cause, which is where the dated solicitation records become evidence.
Withholding itself has its own rules and rate. The post on when backup withholding starts for a missing W-9 covers when it begins, and backup withholding and a missing W-9 covers how it is deposited and reported.
Whether to withhold, pay or stop using a vendor who will not send a W-9 is the client's decision. The firm's job is to make sure the client knows which vendors are missing forms in November, while there is still time to ask.