February 28 Deadlines: The IRS Paper-Filing "Last Call"

For practitioners catering to clients that are eligible to paper-file, February 28 is the quiet but consequential IRS deadline that sits between W-2/1099 delivery season and the March/April crush. In practice, it’s the IRS “last call” for several paper-filed information returns. Since many of these forms also have March 31 e-file deadlines, the real risk is not missing the date, but missing the filing method rules, transmittals, and matching requirements that trigger penalties and notices.

A key calendar nuance for 2026: if February 28 falls on a weekend or legal holiday, the due date shifts to the next business day. For 2025 forms filed in 2026, many paper due dates fall on March 2, 2026.

The paper-filing deadline applies only to taxpayers filing fewer than 10 total information returns (in aggregate). All others must file electronically. E-filing waivers (Form 8508) exist but are granted under exceptional circumstances and must be requested at least 45 days before the due date.

Below are the most prominent February 28 forms, how to file them, and common pitfalls. For quick answers on due dates and form requirements, Feather can help.

1. Form 1099-MISC and Most 1099 Series Forms (Exception: 1099-NEC)

When it applies

Most 1099 series’ information returns filed with the IRS fall under the February 28 paper filing deadline, unless a specific exception applies. These forms report a wide range of payments, including compensation, investment income, distributions, rents, and other reportable transactions.

Where and how to file

• If filing by paper, Copy A must be mailed to the IRS with Form 1096 as the transmittal.
• If filing electronically, the deadline is generally March 31, submitted through the IRS FIRE system or an approved information return provider.

Pitfalls to watch

• Confusing 1099-NEC (due January 31) with 1099-MISC is one of the most common errors and can result in late filing penalties.
• Missing or incorrect TINs can trigger penalty notices and B-notice cycles.
• State reporting is not always automatic; some states use the Combined Federal State Filing Program, while others require separate submission.

2. Forms 1094-C and 1095-C for Applicable Large Employers

When it applies

Applicable Large Employers (ALEs) must file Forms 1094-C and 1095-C to report health coverage offers and compliance with the employer-shared responsibility provisions.

Where and how to file

• Paper filers submit Forms 1094-C and 1095-C directly to the IRS by the February 28 deadline. If an ALE files 10 or more information returns in aggregate, it must file electronically.
• Electronic filers use the IRS AIR system, with a general deadline of March 31. This usually applies to ALEs, since they typically have at least 50 employees.

Pitfalls to watch

• Many employers assume paper filing is simpler; in practice, electronic filing is often required due to volume thresholds. Filing on paper when e-file is required can result in the IRS treating returns as not filed and significant penalties.
• Coding errors between payroll and benefits systems frequently generate IRS Letter 226J notices.
• Mismatches between Form 1094-C totals and attached 1095-C forms are a recurring issue; practitioners should double-check both.

3. Form 8027 for Large Food or Beverage Establishments

When it applies

Restaurants and establishments that meet the IRS definition of a “large” food or beverage establishment must file Form 8027 to report tip income and allocations.

Where and how to file

• Paper filing is due February 28 and requires Form 8027-T if submitting multiple Forms 8027.
• Electronic filing is due March 31.

Pitfalls to watch

• Many businesses overlook this requirement until after W-2s have been issued.
• Tip allocation errors can create downstream payroll corrections.
• Multi-location operations must ensure each establishment is properly reported and reconciled.

Other Paper Filings Tied to February 28

The February 28 paper deadline generally applies to many other information returns, depending on the facts. Such forms may include other 1099 series, certain 1098 series, and Form W-2G. In most cases, electronic filing shifts the deadline to March 31. Technical requirements vary, so confirming due dates and methods before filing is critical. Feather can help you verify due dates and requirements for any information return.

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