Year-End Payroll Reporting: State-by-State Due Dates for Form W-2

The skies are cloudy, the leaves are changing, the air is cool and brisk—and in this profession, that means time to think about year-end prep for payroll departments.

First order of business—purchase W-2 stock. Most vendors have discount pricing and you should either be buying now or placed and received your orders. Remember to order enough stock to cover new hires, new clients (if you are a payroll provider) and an ample supply for corrections and reprints. Don’t underestimate what you need—it can be very difficult and pricy to place an emergency order in mid-January.

Also, don’t forget to order Forms 1094-C and 1095-C if you are an Applicable Large Employer. The issue is that—as of the writing of this article on September 9, 2015—the IRS has not finalized the forms, so you cannot order yet. Keep checking, though, because they will hopefully be available to order soon.

Lately, there’s been a lot of press about accelerated W-2 filing for federal returns. Please be aware that any acceleration of the filing dates (federal paper February 28/29, electronic March 31) will take an Act of Congress. It isn’t expected that the federal W-2 filing will be moved up anytime soon—it’ll probably be 2017 at the earliest for 2016 W-2s, and that doesn’t even look likely at this point.

However, there is a new initiative (JCX-108-15) recently prepared by the staff of the Joint Committee on Taxation on September 11, 2015, that could make this happen in the 2016 tax year with an employer filing date of 15 days after the employee form W-2 distribution deadline (making the deadline February 15).

It’s important to note that state W-2s are a whole other issue. There are several states that now have January 31 as filing dates for state W-2s and more are changing. The states that now require W-2s to be filed electronically by January 31 are: Alabama, Connecticut, Delaware, Illinois, Indiana, Kentucky, Pennsylvania, Utah, Virginia and Wisconsin. More states are expected to follow, and Puerto Rico also has these requirements.

Utah also has a unique stipulation in its tax code, which states that no refunds will be processed until the employer copy is filed and processed.

For your reference, here is a list of the due dates by state.

Electronic State W-2 Due Dates
AL	31-Jan	IL	15-Feb	MT	28-Feb	PR	31-Jan
AK	None	IN	Jan 31 – 2016 new	NE	1-Feb	RI	Last day of Feb
AZ	28-Feb	IA	n/a	NV	None	SC	Last day of Feb
AR	28-Feb	KS	Last day of Feb	NH	None	SD	None
CA	n/a	KY	31-Jan	NJ	Last day of Feb	TN	None
CO	31-Mar	LA	First bus day after Feb 27	NM	Last day of Feb	TX	None
CT	31-Mar	ME	31-Mar	NY	n/a	UT	Jan 31 – 2016
DE	31-Mar	MD	Last day of Feb	NC	Last Day of Feb	VT	28-Feb
DC	31-Jan	MA	31-Mar	ND	31-Mar	VA	31-Jan
FL	None	MI	28-Feb	OH	28-Feb	WA	None
GA	28-Feb	MN	28-Feb	OK	n/a	WV	28-Feb
HI	Last day of Feb	MS	31-Mar	OR	31-Mar	WI	31-Jan
ID	28-Feb	MO	Last day of Feb	PA	31-Jan	WY	None

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James Paille, CPP, is the President Elect of the American Payroll Association and is the director of Operations for Thomson Reuters myPay Solutions. He has been an executive manager in the payroll service industry for over 30 years, specializing in managing multi-location offices. Jim is a member of the APA’s Board of Directors and National Speakers Bureau, and chairs the CPP Certification Review Panel. He holds a BS in Accounting from St. John Fisher College in Rochester, NY. Jim has been married for 34 years to his wife, Alice. He enjoys golf and is an avid Boston Red Sox fan.