Act Now: The IRS Form 1042 E-File Waiver Deadline Is Fast Approaching

Withholding agents that have not secured access to the IRS Modernized e-File platform (“MeF”) should act immediately.   While many will have filed Form 7004 to extend the Form 1042 filing deadline to 15 September 2026, that extension does not waive the IRS electronic filing requirement for tax year 2025.

For filers seeking to file Form 1042 on paper, the written “Form 1042 e-file Waiver Request” must be submitted by 1 August 2026, 45 days before the extended filing deadline. With that deadline fast approaching, paper filing should not be assumed merely because an extension has been filed or MeF access has not yet been secured.

Management should now assess whether the organization can satisfy the IRS's strict hardship waiver requirements. A successful waiver request must demonstrate the efforts made to obtain MeF access, explain why those efforts were unsuccessful, describe the undue hardship associated with e-filing, and outline a clear plan to become e-file ready for future tax years.

Accordingly, paper Form 1042 filing should be treated as a controlled exception, not a default option. The evidence file should support MeF access attempts, provider due diligence, system or authentication constraints, officer approval, future-year remediation and, where relevant, a cost analysis comparing paper filing with the incremental cost of e-filing.

Before 1 August, management should answer three critical questions:

1. Can the organization complete the Form 1042 filing through MeF before 15 September 2026?
2. Can a registered provider, such as S&P Global, facilitate an electronic filing within the required timeframe?
3. If neither is possible, is there sufficient evidence to support a timely hardship waiver request and a defensible paper filing position?

S&P Global welcomes the opportunity to assist withholding agents with Form 1042 e-filing options, provider-supported MeF filing and waiver readiness. With direct experience supporting Form 1042 MeF filings, S&P Global can help filers quickly assess their route, identify practical next steps and strengthen the evidence needed before the deadline. If your organisation has not finalised its Form 1042 filing route, contact S&P Global Tax Solutions now to discuss how we can support your MeF filing strategy and waiver readiness.