IRS lowers mandatory e-filing threshold

On February 23, 2023, the IRS issued final regulations lowering the mandatory electronic filing threshold from 250 forms down to 10 for many tax and information returns filed by businesses with the IRS beginning in 2024. Although the new requirement will not take effect until next year, it has the potential to cause substantial disruption—especially for small employers who were more likely to file using paper forms.

This Alert summarizes the new filing requirements that are applicable to employer sponsors of group health plans and provides an overview of action items.