Vol. 17, 001
January 4, 2015
EY Payroll NewsFlash™
2015 Forms W-2 due dates
On the following pages are the due dates for filing state Forms W-2 for tax year 2015. Note that
changes from tax year 2014 are highlighted in yellow. Blue type indicates that the due date differs
from federal.
As we previously reported (EY Payroll NewsFlash, Vol.16, 335, 12-21-2015), on December 18, 2015,
the President signed into law the Consolidated Appropriations Act of 2016 (H.R. 2029) that, among
other things, accelerates the federal filing due date for Form W-2 effective with returns filed in 2017
(tax year 2016). (See Publication 15, Employer’s Tax Guide, Rev. 2016.)
Despite commentary from business groups that accelerating the Form W-2 filing due date would result
in a significant burden to employers and an increase in reporting errors, H.R. 2029 requires that
effective for tax year 2016 (filed in 2017) the due date for filing Forms W-2/W-3 with the Social
Security Administration is accelerated to January 31 whether filed electronically or on paper.
(Currently the due date for filing paper Forms W-2/W-3 is the last day of February and the due date for
electronically filed forms is March 31.)
In addition, the earlier filing due date of January 31 applies to returns filed with the Internal Revenue
Service to report nonemployee compensation (e.g., Form 1099-MISC). (IRC §6071, new subsection
(c).)
To allow time for the processing and use of employer-provided Form W-2 data by the IRS in
issuing income tax refunds to taxpayers, H.R. 2029 also stipulates that no credit or refund of
a tax overpayment will be made to taxpayers for the tax year before the 15th day of the
second month following the close of s u c h taxable year. (IRC §6402, new subsection (m).)
Watch for more states to require January 31 filing in 2016
In addition to the states that already require a January 31 filing due date, it is anticipated that a
number of states that follow the federal W-2 guidelines will also change their filing due date next year
(e.g.. Colorado, Delaware, Idaho, Maine, North Dakota and Oregon).
Continued on next page.
1
State/jurisdiction
Column 1: employee
Column 2: state
Alabama
January 31
January 31 (10)
Arizona
January 31
February 28
Arkansas
January 31
February 28
California
January 31
January 31 (1)
Colorado
January 31
February 28 (7, 15)
Connecticut
January 31
January 31 (16)
Delaware
January 31
February 28 (5, 15)
District of Columbia
January 31
January 31 (12)
Georgia
January 31
February 28
Hawaii
January 31
February 28 (7)
Idaho
January 31
February 28 (7, 11)
Illinois
January 31
February 15 (14)
Indiana
January 31
January 31 (22)
Iowa
January 31
February 28 (3,7)
Kansas
January 31
February 28 (7)
Kentucky
January 31
January 31
Louisiana
January 31
February 28 (8)
Maine
January 31
February 28 (6,15)
Maryland
January 31
February 28 (5)
Massachusetts
January 31
February 28 (7,15)
Michigan
January 31
February 28
Minnesota
January 31
February 28
Mississippi
January 31
January 31
Missouri
January 31
February 28 (7)
Montana
January 31
February 28
Nebraska
February 1 (17)
February 1 (17)
Column 3: state
electronic filers
March 31
March 31
March 31
March 31
March 31
March 31
2
State/jurisdiction
Column 1: employee
Column 2: state
New Jersey
February 15
February 28 (7, 13)
New Mexico
January 31
February 28 (7, 19)
New York
February 15
January 31 (1)
North Carolina
January 31
January 31 (18)
North Dakota
January 31
February 28 (15)
Ohio
January 31
February 28 (2, 7)
Oklahoma
January 31
n/a (4)
Oregon
January 31
March 31 (15, 21)
Pennsylvania
January 31
January 31
Puerto Rico
January 31
January 31
Rhode Island
January 31
February 28
South Carolina
January 31
February 28 (7)
Utah
January 31
January 31 (20)
Vermont
January 31
February 28
Virgin Islands
January 31
April 1
Virginia
January 31
January 31 (9)
West Virginia
February 15
February 28
Wisconsin
January 31
January 31
Column 3: state
electronic filers
March 31
March 31
Based on Ernst & Young LLP survey results as of December 2015.
* It varies from state to state whether the deadline is extended to the next business day when the deadline falls on a Saturday, Sunday or holiday.
Check with the state taxing authority for more information. There is no state income tax in Alaska, Florida, Nevada, South Dakota, Texas,
Washington or Wyoming. New Hampshire and Tennessee require income tax only from interest and dividends.
Reference chart
(1) California and New York. Forms W-2 are not filed with California; however, employee-level detail is filed quarterly on Form DE 9. New York
also does not require that Forms W-2 be submitted but requires employee-level detail on the quarterly NYS-45.
(2) Ohio. Ohio Form IT-941, Annual Reconciliation of Ohio Income Tax Withheld, is due on January 31. Employers of 250 or more employees
must file Forms W-2 on CD-ROM. Employers of fewer than 250 employees are not required to submit paper copies of Forms W-2 (state Form
IT-2) to the Ohio Department of Taxation. Employers must continue to maintain these records for four years from the due date. Employers
with fewer than 250 employees may choose to voluntarily file Forms W-2 with the Department on CD-ROM. If the employer files Forms W-2
magnetically, Ohio Form IT-3, Transmittal of Wage and Tax Statements, and the magnetic media are due to the Department by February 28.
Effective January 1, 2015, Ohio employers are required to file all withholding tax returns except Forms W-2 electronically. Proposed
3
regulation changes, potentially effective for calendar year 2016 (due in 2017), would require all Ohio employers to also file Forms W-2
electronically.
(3) Forms W-2 are not filed with the state. File annual reconciliations only.
(4) Neither an annual reconciliation report or Forms W-2 need be filed with the state.
(5) An annual reconciliation report is not required if Forms W-2 are filed electronically.
(6) Maine. Maine employers report withheld state income tax on the quarterly tax report. A separate reconciliation return (Form W-3ME) must be
filed by February 28. Employers of 250 or more employees must file Forms W-2 and the annual reconciliation (Form W-3ME) electronically
with Maine Revenue Services. For employers of fewer than 250 employees, Forms W-2 are not required unless the employer fails to report
the W-2 information quarterly.
(7) Due date is February 29 in a leap year.
(8) Louisiana. Due date is first business day following February 27.
(9) Virginia. Effective for calendar year 2014, the deadline for all employers to submit Forms W-2 to the Virginia Department of Taxation
electronically is January 31, rather than the previous February 28.
(10) Alabama. A rule change shortened the deadline for submitting Forms W-2 to January 31, effective for calendar year 2015 (due January 31,
2016).
(11) Idaho. Idaho will no longer extend the deadline to March 31 for electronically filed Forms W-2.
(12) District of Columbia. All Forms W-2 must be submitted by January 31; electronic filers no longer have an extended deadline of the last day of
February. The annual reconciliation form must by law also be submitted by January 31.
(13) New Jersey. Statutory deadline to file is February 15, but administrative policy extends the deadline to the last day of February to match
federal.
(14) Illinois. The Illinois annual reconciliation form is no longer required. Employers required to file Form W-2 information electronically with the
SSA, as well as all payroll service providers, are required to file electronically with the Illinois Department of Revenue no later than February
15 (March 31 prior to tax year 2014). Employers not required to file electronically with the SSA need not submit Forms W-2.
(15) The deadline is extended to March 31 for Forms W-2 filed electronically.
(16) Connecticut. Effective in 2014, all employers must file all withholding returns, including Form W-2 and the annual reconciliation (unless
administratively waived), electronically. Employers that have requested a waiver of the requirement to file electronically must file on CD.
Effective July 1, 2015, employers are required to electronically file Connecticut Form CT-W-3, Connecticut Annual Reconciliation of
Withholding, and the corresponding Forms W-2 by January 31, rather than the previous deadline of February 28 for paper Forms W-2 and
March 31 for electronically filed Forms W-2.
(17) Nebraska. The deadline for employer submission of Forms W-2 information to the Nebraska Department of Revenue changed from March 15
to on or before February 1, effective January 1, 2011. Effective for calendar year 2014, employers must provide Forms W-2 to employees
on or before February 1.
(18) North Carolina. Legislation (HB 117) enacted on September 30, 2015 requires employers to electronically file Forms W-2 with the
Department of Revenue by January 31, beginning with calendar year 2015. However, because all of the electronic filing options will not be
available by January 1, 2016, the Department is waiving the electronic filing requirement for calendar year 2015, due January 31, 2016.
(19) New Mexico. Employers that file a Form ES-903, Wage and Contribution Report, to the New Mexico Workforce Solutions Department or Form
TRD-31109 to the Taxation and Revenue Department do not need to submit Forms W-2 or the annual reconciliation form to the state.
(20) Utah. Effective January 1, 2016, and effective for calendar year 2015, all employers must file Form TC-941R, Utah Annual Withholding
Reconciliation, and corresponding Forms W-2 (and 1099 with Utah taxes withheld) electronically by an accelerated due date of January 31,
changed from February 28 for paper forms and March 31 for electronically filed forms. Failure to do so may result in penalties of up to $100
per form.
(21) Oregon. All employers must file Forms W-2 electronically beginning with calendar year 2011. Paper Forms W-2 are not filed.
(22) Indiana. Effective July 1, 2015, Indiana employers must file Form WH-3, Annual Withholding Reconciliation, with the Indiana Department of
Revenue not later than 31 days after the end of the calendar year. As a result, the due date for Form WH-3 and corresponding Forms W-2 is
changed to January 31, accelerated from February 28.
4
For information concerning this EY Payroll NewsFlash contact [email protected] or
[email protected]
_____________________________________________________________________________________
The information contained herein is general in nature and is not intended, and should not be construed, as legal,
accounting or tax advice or opinion provided by Ernst & Young LLP to the reader. The reader is also cautioned that
this material may not be applicable to, or suitable for, the reader's specific circumstances or needs, and may
require consideration of non-tax and other tax factors if any action is to be contemplated. The reader should
contact his or her Ernst and Young LLP or other tax professional prior to taking any action based upon this
information. Ernst & Young LLP assumes no obligation to inform the reader of any changes in tax laws or other
factors that could affect the information contained herein. Copyright 2016. Ernst & Young LLP. All rights
reserved. No part of this document may be reproduced, retransmitted or otherwise redistributed in any form or by
any means, electronic or mechanical, including by photocopying, facsimile transmission, recording, rekeying, or
using any information storage and retrieval system, without written permission from Ernst & Young LLP.
5