Episode 42: Substitute Forms, A Bigger 1099 Deal than You'd Think
The IRS has released Revenue Procedure 2026-18, its annual guidance on substitute forms — and despite the somewhat obscure name, the rules can affect virtually anyone responsible for filing or furnishing Forms 1099.
What Is a Substitute Form?
A substitute form is an information return produced in a format other than the official form supplied by the IRS. The IRS publishes detailed specifications governing how these forms must look and what information they must contain.
For organizations that e-file their information returns with the IRS, this generally isn't something to worry about on the filing side. Whether you're filing directly through IRIS or using third-party software, the electronic filing process takes care of the IRS filing specifications.
Paper filing is different. You generally cannot download Copy A of a Form 1099 from the IRS website, print it on ordinary paper, and mail it to the IRS. Paper filings must meet the IRS's specifications, which is why organizations that still file on paper typically use the special forms available from office-supply stores or other forms providers.
But substitute-form rules don't stop with the IRS copy.
Recipient Copies Count, Too
The rules also apply to the statements furnished to recipients.
That means organizations need to pay attention to the format of the Forms 1099 they provide to contractors, vendors, and other recipients — whether those statements are furnished on paper or electronically.
If you prepare returns directly through IRIS and download the recipient PDF generated by the system, you're fine using that version. But in general, you can't simply put the relevant information on a piece of paper and call it a Form 1099. Recipient statements must meet IRS requirements.
A Change to Address Fields
Revenue Procedure 2026-18 highlights a change that has also appeared on some of the newer Forms 1099: address information is being separated into individual fields rather than appearing in one large address box.
City, state, ZIP code, and other components now have their own fields.
When these changes first appeared on forms such as the 2026 Forms 1099-NEC and 1099-MISC, they looked largely cosmetic. Their inclusion in the substitute-form revenue procedure suggests there may be more to the change, potentially including implications for IRIS, although the IRS has not provided enough information yet to say definitively.
Welcome to the Information Return Family
Revenue Procedure 2026-18 also identifies several additions to the information-return lineup:
- Form 1098-VLI, for reporting certain qualified passenger vehicle loan interest.
- Form 1099-LPS, relating to long-term care premiums paid.
- Form 5498-TA, relating to Trump account contributions.
- Form 1099-DA, for digital asset reporting. Although Form 1099-DA first came into use for 2025 reporting, the IRS continues to list it among the new forms in this revenue procedure.
Meanwhile, one form has officially been put out to pasture: Form 1098-MA. The form related to the Hardest Hit Fund, Short Refinance, and Making Home Affordable programs. With funding for those programs expired, the form has been retired as well.
The Takeaway
If you e-file your Forms 1099 with the IRS, the substitute-form rules generally aren't something you need to think about when transmitting the returns to the government.
But if you paper file with the IRS, the rules matter.
And regardless of how you file with the IRS, they also matter when you furnish statements to recipients.
Revenue Procedure 2026-18 gets deep into technical specifications that most organizations will never need to study line by line. But the broader lesson applies to everyone: a Form 1099 isn't simply a collection of numbers and names. The format matters, too.
Listen to this week's Information Return Intelligence, powered by IOFM, for more on Revenue Procedure 2026-18 and what the substitute-form rules mean for information return filers.
The IRS has released its annual revenue procedure where it talks about what are called substitute forms. This actually affects anybody who files a 1099, and we will talk about it this week on Information Return Intelligence powered by IOFM. Before we get started with this week's show, a few disclaimers. This is not tax advice, and I am not your accountant. Never make final decisions based on anything you see or hear in this podcast. Always pay your own advisors before making final decisions. With those disclaimers out of the way, let's get started with information return intelligence. This week's show is all about revenue procedure 2026-18, which is the IRS revenue procedure that they put out at least once a year relating to substitute forms. So what is a substitute form? Substitute forms apply anytime you're sending a 1099 out in any format to anyone. It has to be in the proper format as approved by the IRS. Now when you e-file with the IRS, which I'm sure many, if not most of you do, then this whole substitute forms thing, it's a moot point because you're e-filing with the IRS and that meets the substitute forms rules. You're e-filing in Iris or whatever third-party provider or software you're using to get things sent off to Iris, and so it's kind of a moot point. But then you have sending the 1099 to the recipient, like getting the 1099 NEC to your contractor, those sorts of things have to meet IRS specifications. So this comes into play if you happen to be paper filing with the IRS, which some of you still do. If you paper file, you have to make sure you're meeting specifications. And basically, if you're printing to the pre-printed forms you buy at the office store, you're okay when you're mailing stuff to the IRS. What you can't do if you're paper filing with the IRS, you can't just fill out the PDFs on the IRS website and print those off and send them in. It has to be on special paper, and you don't have to buy it at the office store. There's other places you can get it, but office stores are one place where you can get this paper. And you have to print it that way if you're paper filing with the IRS. And then you have forms that you send to your recipient, which apply both to paper versions that you're printing and sending to them or giving to them, or to anything that you might be sending electronically. It has to meet IRS specifications. So that's what we're talking about when we say a substitute form. So the IRS puts out this revenue procedure once a year that tells us all about the layouts and so forth, and also gives us other information about information forms. Now we're not going to get into all of the specifications. I mean, the revenue procedure gets pretty detailed with layouts and so forth. We're not getting into all that, but we will talk about what's new in that document. The thing that's listed under what's new as far as an operational thing relates to address fields. We've talked about this before because I had noted it on some of the 1099 NEC and 1099 miscellaneous versions that the IRS was putting out for 2026. And that is the address fields, each item in an address now has its own box. So previously, the address area of the 1099, it was just a big box where you put everything. And now each item is broken out in a separate box. So city, state, zip, it all has its own separate box. And I had said when we were talking about the 2026 versions of 1099 NEC and 1099 Miscellaneous a couple of months ago, that it seemed like that was just a cosmetic change. Now that it's in this revenue procedure on substitute forms, I would amend what I said earlier and say it might just be cosmetic, or maybe it has some relevance like within Iris. I've tried checking on that and I can't find anything specific. So I would say it might just be cosmetic, or maybe it'll have some relevance within Iris. We'll have to wait and see. And now a word from our sponsor. The Institute of Finance and Management has certified over 25,000 financial operations professionals worldwide through its four certification programs. These programs include accredited payable specialist or manager with US and Canadian specific versions available, accredited receivables specialist or manager, certified professional controller, and certified payment reporting specialist. That's the 1099 certification that I teach. These globally recognized certifications are available in English, simple Chinese, and Spanish. Learn more at IOFM.com. And now back to the show. The document also tells us what's new as far as new forms go, so we can celebrate four new additions to the information return family. We have Form 1098 VLI, which is issued by lenders to people who have certain auto loans. That's all we'll say about it for today. If you are a bank that makes car loans, or you're some other lender that does car loans, or you're a dealership that does financing, this would be a form that you might have to issue. There's a new form called a 1099 LPS, which relates to long-term care premiums paid. Form 5498 TA, which relates to Trump account contributions, and Form 1099 DA for digital asset reporting. Now that was really new for 2025, but the IRS still lists it under what's new in Revenue Procedure 2026-18. And there's one form that's been retired and taken out of service, put out to pasture, and that's Form 1098 MA, which relates to the hardest hit fund, short refinance, and making homes affordable programs. Funding for those programs has expired and run out, so these programs don't exist anymore, and therefore this form no longer exists. So to recap this substitute forms stuff. Except you still need to be aware of this for forms that you send to the recipient. One thing I didn't say earlier was say that you do it yourself in Iris, and then Iris lets you download a PDF of what you filed, and you can print it off on plain paper and send it to your contractor, and that's okay. Whatever iris gives you is going to be okay to then give to the other party. But you just have to have this in mind that you can't just like write down on a piece of paper and hand it to someone and call it good for meeting your 1099 obligations. You have to put at least a little bit of thought into what are we giving to people. That's what substitute forms are all about. Thanks for listening to or watching another episode of Information Return Intelligence powered by IOFM. We do this every week where we talk about different things relating to 1099s. You can find all of our podcasts at podcasts.dynasonmedia.com. I'm Jason Dinason. Join us again next week, Dinason Media Ventures.