The Government Relations Office has recently been contacted by members expressing concern over the Illinois Department of Revenue’s (IDOR) late notice of new employer electronic filing requirements of employee W-2 forms. In December, 2017 IDOR issued Informational Bulletin 2018-18 outlining electronic filing requirements for withholding income tax.

Public Act 100-303, signed into law on July, 2017, amended the Illinois Income Tax Act relating to electronic filing. Included in the legislation was a provision requiring employers to file W-2s electronically starting with the 2017 tax year.  The basis of this new requirement is another tool to prevent fraudulent tax return filings. 
While ICPAS Government Relations included notice in the October issue of Capitol Dispatch regarding this new requirement, ICPAS has voiced concern to the Illinois Department of Revenue over the lack of awareness and late notice to employers of this new filing requirement.
Businesses that make a reasonable good faith effort to comply with the electronic filing deadline may file a reasonable cause request with the department if they are penalized for failure to file electronically. Additionally, the Informational Bulletin and IDOR website specify that businesses and employers can, in certain instances, request waivers from the new electronic filing requirement.
We wanted to provide you this information out of an abundance of caution and to respond to the concerns that you may have.