New W-9 Form 2026: What Changed? (2018 vs 2024 vs June 2026 Draft)
Is there a new W-9 form for 2026? Learn what changed in the current Rev. March 2024 form (Line 3b), how the Rev. June 2026 IRS draft affects digital asset brokers, and how the $2,000 OBBBA threshold impacts your business.
- Form W-9 (Rev. March 2024) is the active, official IRS standard for all vendor and contractor onboarding.
- The IRS published an advance "Rev. June 2026 draft" (released May 4, 2026) for crypto brokers—do NOT use draft forms for general filing.
- October 2018 forms on file remain valid for existing continuous vendors, but businesses must reject them for new onboarding.
- Line 3b is a mandatory disclosure for partnerships and trusts with foreign owners (supporting Schedules K-2 and K-3).
- Single-member LLCs must check the tax classification of their owner (usually Individual/sole proprietor), never the LLC box.
- Under the OBBBA, the 1099-NEC threshold is $2,000 for 2026 payments ($600 applies to 2025 payments filed in early 2026).
- Failing to collect a valid W-9 triggers mandatory 24% backup withholding liabilities under IRC § 3406.
Is there a new W-9 form for 2026?
If you are searching for an updated W-9 form 2026, here is the official IRS reality: Form W-9 (Rev. March 2024) is the current, active version you must use in 2026 for all standard vendor and contractor onboarding.
The confusion comes from two different IRS updates circulating among accounting departments:
- The Rev. March 2024 Overhaul (Active Standard): This is the official form containing the mandatory Line 3b foreign partner disclosure and clarified single-member LLC rules. This is the version businesses must demand from all newly onboarded payees.
- The Rev. June 2026 Draft Form (Advance Release): On May 4, 2026, the IRS released a draft revision (marked "Rev. June 2026", superseding the earlier January 2026 draft). This draft introduces specific certifications for cryptocurrency and digital asset brokers under Form 1099-DA. However, the IRS explicitly prohibits filing draft forms—standard businesses must continue using the March 2024 revision.
If a vendor submits an obsolete October 2018 form today, you should reject it. While older forms in your archive remain valid for existing, continuous vendor relationships, onboarding new payees with outdated paperwork creates severe compliance blind spots under current IRS rules.
Who receives a W-9 and when should you request it?
The business engaging the contractor receives it. A freelancer, single-member LLC, or independent vendor submits a completed W-9 to every client they expect to invoice.
Collect the form before issuing the first payment, never at year-end. Chasing down a missing W-9 in mid-January when 1099 deadlines loom leads to backup withholding liabilities and administrative gridlock. Our comprehensive guide on W-9 vs. 1099 outlines how the two documents connect in the annual tax filing cycle.
When should you NOT request a W-9?
You do not need a W-9 when the worker is a standard payroll employee, because they complete Form W-4 instead. You also do not need one when paying a C Corporation or S Corporation for standard commercial services (outside medical or legal payments). Furthermore, foreign contractors living outside the U.S. do not submit a W-9; they provide Form W-8BEN or W-8BEN-E to certify non-U.S. tax status.
Side-by-side comparison: 2018 vs. 2024 vs. June 2026 draft
The table below compares how the IRS modified key lines, entity classifications, and digital asset reporting across each version:
| Form Line / Feature | Rev. October 2018 | Rev. March 2024 (Active Official) | Rev. June 2026 Draft (Advance) |
|---|---|---|---|
| Legal Status | Obsolete for new vendor onboarding | Mandatory active standard for 2026 | Advance draft (Do not file for general use) |
| Line 3a (Disregarded LLCs) | Ambiguous instructions; caused high error rate | Explicitly requires owner tax classification | Maintains March 2024 single-member LLC rules |
| Line 3b (Foreign Partners) | Did not exist | Mandatory disclosure for flow-through entities | Retained from March 2024 standard |
| Part II Broker Certification | None | None | New checkbox for Form 1099-DA broker exemption |
| Exempt Payee Code 14 | None | None | Redefined as U.S. digital asset broker entity code |
The October 2018 form: The single-member LLC trap
For over five years, Form W-9 (Rev. October 2018) served as the default standard. The problem with the 2018 form was not what it asked, but what it failed to clarify.
The most common compliance breakdown occurred on Line 3regarding tax classification. Freelancers operating a single-member LLC routinely checked the "Limited liability company" box and entered "D" or "P".
That is legally incorrect for federal tax purposes. A single-member LLC is classified by default as a disregarded entity. The business income flows straight through to the owner's personal Form 1040 Schedule C.
When a disregarded LLC checks the LLC box on the 2018 form, accounts payable systems mistakenly file year-end 1099-NEC forms under the LLC name and EIN instead of the individual owner name and SSN. This triggers an automated IRS CP2100 Notice (B-Notice), demanding backup withholding due to a name/TIN mismatch.
For complete instructions on classifying disregarded entities correctly, read our guide on how to fill out a W-9 for an LLC.
The March 2024 revision: Line 3b and foreign partner rules
In March 2024, the IRS released a substantive overhaul. The first change clarifies Line 3a, explicitly instructing single-member LLC owners to select the tax classification of their owner (usually "Individual/sole proprietor").
The major structural addition is Line 3b:
“If on line 3a you checked ‘Partnership’, ‘Trust/estate’, or ‘LLC’ with a tax classification of ‘P’, check this box if you have any foreign partners, owners, or beneficiaries.”
Line 3b applies strictly to flow-through entities. If a payee checks "Partnership", "Trust/estate", or enters "P" on Line 3a, they must review Line 3b. If that entity has any direct or indirect foreign partners, owners, or beneficiaries, they must check the box.
Why does the IRS care about foreign partners on a domestic W-9? It connects directly to Schedules K-2 and K-3 (Form 1065). When a partnership pays another partnership with foreign owners, the IRS needs full transparency to trace international tax obligations. Line 3b places the legal duty on the flow-through entity to declare foreign ties under penalties of perjury.
The Rev. June 2026 draft form: Digital assets & Code 14
To enforce digital asset reporting under the Infrastructure Investment and Jobs Act (IRC § 6045), the IRS published an advance draft revision marked "Rev. June 2026" on May 4, 2026, superseding earlier early-release drafts.
This draft update introduces critical compliance mechanisms for cryptocurrency exchanges and custodial brokers reporting on the new Form 1099-DA:
- Part II Broker Certification Checkbox: Under the certification section, a digital asset broker can certify to another broker that they qualify as an exempt U.S. digital asset broker under Treas. Reg. § 1.6045-1(c)(3)(i)(B)(12), preventing duplicate 1099-DA reporting.
- Exempt Payee Code 14 Reclassification:While the initial January draft signaled Code 14 for backup withholding relief under Notice 2025-33, the subsequent Rev. June 2026 draft instructions (tracked in KPMG analysis) redefined Code 14 as a general entity classification code for a "U.S. digital asset broker". Because this remains a draft, practitioners should monitor final IRS requester instructions before applying draft codes.
- Substitute Form Rules: A substitute W-9 without the crypto checkbox remains fully valid for non-broker commercial vendors.
Unless you operate a digital asset brokerage, do not use draft forms. Standard commercial businesses must continue using the finalized Rev. March 2024 form. If you need a certified blank copy, you can generate a free fillable W-9 form online in minutes.
The 24% backup withholding penalty & the $2,000 OBBBA threshold
Why should an accounts payable team care if an onboarding vendor hands them an old 2018 PDF? Because Form W-9 is your legal protection against 24% backup withholding liabilities.
Under federal tax law, businesses must file Form 1099-NEC when paying an independent contractor $2,000 or more in 2026 under the One Big Beautiful Bill Act (OBBBA), while the historical $600 threshold applies to 2025 payments filed in early 2026. Regardless of whether total compensation crosses the $2,000 threshold, you must collect a certified TIN upfront to verify payee identity and establish exemption from backup withholding.
If you onboard a contractor without a valid W-9—or if they provide an invalid document that fails IRS TIN matching—the law requires you to initiate 24% backup withholding immediately under IRC § 3406.
If you fail to withhold that 24%, the IRS does not pursue the contractor—they assess the full 24% tax penalty directly against your business, along with failure-to-deposit penalties under IRC § 6656. Learn more about your legal obligations in our guide on what to do when a contractor refuses a W-9.
Accounts payable: 30-second W-9 audit checklist
Protect your business from year-end 1099 errors by running every incoming W-9 through this quick verification process:
Look at the top-left corner. Ensure it reads "Rev. March 2024". If it reads 2018, reject it and request the current version.
Line 1 must contain the individual or legal owner name. Line 2 contains the DBA or LLC name. Never leave Line 1 blank.
If Line 3a is checked as a Partnership or Trust, confirm whether Line 3b is checked or verified as having zero foreign partners.
Part II must feature a physical or compliant electronic signature under penalties of perjury. An unsigned W-9 is legally void.
Related W-9 & tax compliance guides
Explore our library of verified IRS guidance for independent contractors, payroll teams, and employers: