This blog was last updated on July 31, 2026

I’ve been thinking about the bipartisan legislation introduced by Senators Maggie Hassan and Chuck Grassley that would accelerate the IRS filing deadline for several information returns from March 31 to January 31. 

Most of the discussion surrounding the proposal has focused on what it means for the IRS. That’s understandable. The objective is straightforward: provide the IRS with third-party information earlier so it can better match taxpayer returns before refunds are issued, identify discrepancies sooner, reduce identity theft and refund fraud, and strengthen overall tax administration. Congress followed this same philosophy with the PATH Act of 2015 when it accelerated the filing deadlines for Forms W-2 and Form 1099-NEC. 

This proposal also isn’t new. Accelerating additional information return filing deadlines has been recommended by the Electronic Tax Administration Advisory Committee (ETAAC) in multiple annual reports to Congress as a way to improve return matching, reduce fraud, and strengthen electronic tax administration. It’s part of a broader discussion that’s been underway for several years about modernizing the information reporting framework. 

From a tax administration perspective, the proposal makes sense. What I haven’t seen discussed very much is what happens inside the businesses responsible for producing those information returns. 

The Current Information Reporting Process Didn’t Happen by Accident 

Information reporting processes didn’t evolve randomly over the last several decades. Businesses built them around the statutory framework Congress established. 

Today, organizations furnish recipient statements by January 31 and, for many information returns, electronically file with the IRS by March 31. That two-month period between furnishing statements and filing with the IRS has become an important part of the reporting process. 

It’s easy to assume February and March simply provide additional time to submit a filing, but that’s not really what’s happening. Those weeks are often spent improving the quality of the information ultimately reported to the IRS. Recipient inquiries uncover issues that weren’t identified during testing. Data is reconciled across multiple source systems. Missing or incorrect taxpayer information is researched and updated. Exceptions are resolved. Reporting files are refined. By the time many organizations submit their IRS filing, the data is often significantly cleaner than it was on January 31. 

Businesses didn’t create today’s reporting process by choice. They created it in response to the statutory framework Congress established. 

The Work Doesn’t Go Away. It Moves. 

Changing the filing deadline doesn’t eliminate any of that work. 

Businesses still have to collect data, reconcile information across multiple systems, validate taxpayer information, apply reporting rules, resolve exceptions, and produce accurate information returns. The difference is that much of the work traditionally performed in February and March would now need to happen before January 31. 

One thing I’ve learned over the years is that tax reporting teams rarely own the data they’re responsible for reporting. Information returns are built from data originating in core banking systems, accounts payable platforms, retirement systems, treasury management systems, trust applications, and countless other operational systems across an organization. Before that information ever appears on a Form 1099, it must be consolidated, standardized, validated, reconciled, and transformed into reportable tax data for recipients, the IRS, and state tax agencies. 

Moving the IRS filing deadline forward doesn’t simply ask tax departments to work faster. It changes how businesses prepare for filing season. 

Organizations will move more validation activities throughout the year rather than concentrating them after year-end. They’ll invest in stronger data governance, earlier testing, improved controls over source systems, automation, and technologies that identify issues before filing season begins. Some organizations may add resources. Others may redesign internal processes or rely more heavily on managed service providers. 

Businesses won’t simply compress two months of work into January. They’ll change how information reporting gets done. 

That’s what I find most interesting about this proposal. 

The IRS is trying to improve tax administration. Businesses will respond by redesigning the processes that produce tax information. 

If We Modernize the Filing Deadline, Should We Modernize the Rest of the Framework? 

This proposal also raises a broader policy question. 

The filing deadline doesn’t exist in isolation. Over time, Congress and Treasury have built an entire compliance framework around it, including filing deadlines, penalty provisions under Section 6721, automatic extension of time to file returns procedures under Section 6081, and administrative relief such as the Section 6721 de minimis safe harbor. 

If one of the foundational dates in that framework changes, it’s reasonable to ask whether the surrounding provisions should be evaluated as well. 

Section 6721 is one example. Under today’s framework, businesses generally have a period of time between furnishing recipient statements and filing with the IRS to identify issues, improve data quality, and submit a more accurate filing. If the IRS filing deadline moves to January 31, businesses won’t suddenly stop finding errors after that date. Recipient inquiries will still occur. Reconciliations will still uncover issues. Source systems will still require corrections. The difference is that many of those issues will now be identified after the statutory filing deadline instead of before it. 

That leads me to wonder whether the next step in modernizing the compliance framework is a limited post-filing validation period. Businesses would still be required to file by January 31, preserving the IRS’s objective of receiving information earlier. However, organizations that promptly identify and voluntarily correct material errors within a defined period could do so before the Section 6721 penalty tiers begin to accrue. 

The objective shouldn’t be to give businesses more time to file. The objective should be to encourage businesses to file on time and continue improving the quality of the information reported to the IRS. 

Section 6081 raises similar questions. Today, many information returns are eligible for an automatic 30-day extension of time to file. That process was developed around a March 31 filing framework. If Congress determines that January 31 is now the appropriate statutory deadline, it seems equally appropriate to evaluate whether the current extension process continues to support that policy objective or whether it should evolve as well. 

I’m not suggesting Congress should abandon the proposal. Nor am I suggesting businesses shouldn’t be expected to file timely and accurate information returns. 

What I am suggesting is that if Congress changes one of the foundational dates in the information reporting calendar, this may also be the right time to evaluate whether the broader compliance framework still works together as intended. 

The Real Story 

Tax law has always influenced business behavior. 

Every significant legislative change eventually finds its way into business processes, technology investments, data governance, operational priorities, and organizational structure. Businesses adapt because they have to. 

Information reporting has never really been about tax forms. It’s about data. The tax forms are simply the final product of dozens of business processes operating across an organization. When Congress changes a filing deadline, businesses don’t redesign the forms. They redesign the systems and processes that produce the data behind those forms. 

In many ways, I think this proposal reflects a broader trend. Congress, Treasury, the IRS, ETAAC, and oversight organizations have all been looking at ways to modernize information reporting to improve tax administration. Earlier filing deadlines are one piece of that discussion. The opportunity now is to think just as broadly about the rest of the compliance framework- penalties, extensions, correction mechanisms, and other provisions that were built around a different filing calendar.  

If we’re going to modernize information reporting, let’s modernize it thoughtfully.