Bookkeepers and 1099 Forms: Should They Prepare IRS Documents for Clients?

I belong to a couple of bookkeeping communities on Facebook. We discuss everything from tech issues to getting more clients to pricing services to pep talks on staying the course. Starting sometime in December, I would say that 85 to 90 percent of the discussions were in response to questions about 1099s(and its sister form, the W-9).


This prompted the founder of one of the groups to create a poll asking, “Should Bookkeepers Prepare 1099s”? As of the writing of this post, the overwhelming majority say “Yes”.


The comment section turned into a lively discussion with various opinions on why bookkeepers should or should not prepare 1099s. Comments ranged from 1099s being a regulatory requirement to only if the client reviews and approves to it being a normal part of the year round accounting life cycle.


If you aren’t familiar, here’s a little background on 1099s. They are a collection of tax forms used to report certain types of non-employment income to the IRS. So if a business pays a freelancer or independent contractor to perform work for them, the business must issue the person(or entity) a 1099-NEC. They are also referred to as an information return since they are used to collect and report income data to the IRS. Most of the forms are due on January 31st of each year for the previous year’s income. The IRS takes these forms very seriously and there can be substantial penalties for non-compliance.


As of 2023, the IRS lists more than 20 different 1099 forms. 1099-NEC, 1099-MISC, 1099-INT, 1099-DIV, 1099-G, 1099-K, just to name a few. Depending on the complexity of your client’s business dealings, the task of completing and filing 1099s can either be simple and straightforward or a pulling-out-your-hair ordeal.


So, should bookkeepers prepare 1099s? Perhaps. Can bookkeepers prepare 1099s? Maybe.

 

Bookkeepers should not be obligated to handle 1099s for clients since it falls outside the standard bookkeeping purview. Given the serious consequences of non-compliance, bookkeepers must exercise caution before assuming this responsibility.


However, I don’t see a problem with bookkeepers offering 1099 preparation as an additional service or part of a package as long as specific boundaries are put in place. My concern lies in the knowledge gap among many bookkeepers regarding a basic understanding of the form and IRS regulations.


As I stated above, about 90% of the questions in the bookkeeping groups since December were 1099 related and most were basic and could be addressed by consulting the IRS publications. Prevalent questions were:


“What’s the difference between a 1099-NEC and a 1099-MISC?” 

“Do I have to file a form if the person was paid via a credit card?” 

“My client didn’t collect a W-9 from a contractor. What do I do”? 

“Do I file a 1099-MISC or 1099-NEC for a law firm?”

 

My concern with bookkeepers preparing 1099s isn’t their capability but their lack of fundamental knowledge about the form. If taking on this responsibility, bookkeepers must commit to educating themselves and staying updated on IRS rules related to 1099s.


Also, some bookkeepers may inadvertently limit their knowledge by solely relying on their favorite bookkeeping groups for information, potentially missing out on valuable insights available through additional research channels. While Facebook groups can be a treasure trove of insights from experienced entrepreneurs, demonstrating initiative to research independently and actively seeking information beyond the confines of familiar online communities is essential for a comprehensive understanding of 1099s and effective preparation.


Here are my tips if you’re going to take on 1099s for clients:


  1. Check your E&O coverage: Every bookkeeper should have Errors and Omissions(E&O) Insurance. It’s professional liability insurance that protects your business against claims of inadequate work or negligent actions.  Most carriers have separate policies for bookkeepers and tax preparers and since 1099s are considered a type of tax form, you may want to check with your servicer to make sure preparing 1099s is covered.
  2. Spell everything out in your engagement letter: Never underestimate the power of clarity! 1099s can carry hefty penalties, so it’s imperative to make sure you include specific language in your contract outlining your responsibilities and those of the client. Make it clear that ultimately ownership and compliance with 1099 regulations lies with the client and not you, the bookkeeper. Consider making 1099 preparation an add-on service instead of an automatic inclusion in a package.
  3. Become friends the IRS website: There’s no better place for you to start your 1099 education but on the site of the organization who originated the process. IRS.gov is your one-stop shop for all things tax related but it will be your go-to source for understanding the who, what, when and why of 1099s.
  4. Create a system for collecting W-9s: Proactive organization is your ally. W-9s are the sister forms to 1099s. In fact, they are the forms that will tell you whether you will need to prepare a 1099 for a vendor or independent contractor. While it’s possible to file without a W-9, it complicates the process. Develop a systematic approach to regularly check for W-9s, recording the information in your accounting software or a spreadsheet. Consistent management throughout the year is the key.
  5. Start Early: 1099-NEC and 1099-MISC are due on January 31st each year. This is the due date for filing with the IRS and the recipient receiving a copy. Even if you have a flawless system in place, “what can go wrong, will…”. There are bound to be hiccups from time to time and those unusual issues that come up. Starting early can give you a little extra time to address those special situations and still meet the deadline.
  6. Don’t take on more than you can handle: Know your limits and set honest expectations. Remember…there are 20+ 1099 forms of varying complexity. Attempting to master each one may not be realistic. If you’re considering offering 1099 preparation as a service, focus on the simpler forms like the NEC or MISC, perhaps even the INT. Be honest about your capabilities with clients from the beginning. It’s up to them to decide if they want to engage you for the service or seek alternatives.

1099 season is no joke. It can either be a smooth, uneventful process or the bane of a bookkeeper’s existence. If you’re taking on the challenge, do right by your clients, contractors, and yourself – get educated, be prepared to put in the work, and set up a system that delivers the right results.