Q: Can districts provide employees with an electronic W-2?
A: Yes, employers are permitted to distribute electronic forms in addition to the paper form.
The Internal Revenue Service (IRS) permits employers to set up a system to furnish Form W-2 electronically to employees but requires each employee participating to consent, either electronically or by paper form, to only receive his or her form this way. In addition, the employer must notify the employee of hardware and software needed to receive the form. Employees who don’t consent or withdraw previously provided consent must be given a paper form.
IRS Publication 15-A (2019) provides a list of disclosure requirements that must be meet and communicated to employees in a clear and concise statement when providing electronic forms. Employees must be informed of the following:
- That he or she will receive a paper Form W-2 if consent isn't given to receive it electronically.
- The scope and duration of the consent.
- Any procedure for obtaining a paper copy of his or her Form W-2 and whether the request for a paper statement is treated as a withdrawal of his or her consent to receiving his or her Form W-2 electronically.
- How to withdraw a consent and the effective date and manner by which the employer will confirm the withdrawn consent. The employee must also be notified that the withdrawn consent doesn't apply to the previously issued Forms W-2.
- Any conditions under which electronic Forms W-2 will no longer be furnished (for example, termination of employment).
- Any procedures for updating his or her contact information that enables the employer to provide electronic Forms W-2.
- Any changes to the employer's contact information.
The deadline for providing electronic statement is the same as paper forms. Forms should be mailed out to employees by no later than January 31. While employees may not receive them in the mail on this date, they must be sent out by this point.
Moving to electronic distribution of Form W-2 requires planning. Unfortunately, IRS rules prevent employers from completely eliminating paper forms. However, if you follow the steps above and provide employees with required disclosure, you may reduce the number of paper forms you must send.
April Mabry oversees HR Services training services, member library products, and the HRX newsletter. She has provided HR training and guidance to Texas public schools since 1991. Mabry was a classroom teacher for 11 years in Texas and Michigan.
Mabry has a bachelor’s degree in education from the University of Michigan and certification as a professional in human resources (PHR) and is a SHRM-CP.
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