Episode 9: Proposed Changes to Form W-9: What AP Teams Need to Know Now

In this episode of Information Return Intelligence, host Jason Dinesen is joined by Deborah Richardson, nationally recognized accounts payable consultant, speaker, and trainer, to break down a draft revision of Form W-9 that could have significant implications for vendor setup and 1099 compliance.

While the IRS has not yet finalized the form, the proposed change is more consequential than it may appear at first glance—particularly for individuals and sole proprietors.

🔍 The Key Proposed Change

Under the draft Form W-9, vendors classified as individuals or sole proprietors would be required to provide a Social Security number (SSN) rather than an Employer Identification Number (EIN).

Jason and Deborah explain:

Why this change likely targets single-member LLCs taxed as sole proprietors

How it could affect existing W-9s already on file

Why this may create real-world friction for AP departments—even if the rule itself is technically simple

🧠 What AP Departments Should Be Doing Now

Even though the form is still in draft status, this episode outlines practical steps AP teams should consider:

Don’t panic—the IRS has not finalized or announced an effective date

Bookmark the official IRS W-9 PDF, not just the webpage, to catch silent updates

Continue focusing on timely 1099 and 1042 reporting obligations

Ensure TIN matching and vendor master data accuracy are already solid

🔁 Re-soliciting W-9s: Will You Have To?

One of the most important discussions in the episode centers on whether AP teams may need to re-solicit W-9s from existing vendors who:

Are individuals or sole proprietors, and

Previously provided an EIN

Deborah and Jason discuss:

How system limitations may make identification difficult

Why this change could be different from prior W-9 revisions

The importance of consulting internal leadership and tax advisors before launching large-scale re-solicitation projects

🔐 Data Security Considerations

Because this change may increase the collection of SSNs, the episode also dives into data security best practices, including:

Why email is a high-risk method for collecting W-9s

Using secure email platforms, portals, or SharePoint-style solutions

Reducing unnecessary internal exposure to sensitive vendor data

The value of documented procedures for vendor setup and maintenance

🧾 A Case for Substitute W-9s

Deborah also explains why substitute W-9 / vendor setup forms can be especially valuable when IRS forms change—and what compliance requirements companies must meet when using them.

🎧 Final Takeaway

This episode reinforces a familiar reality in information reporting:

The IRS doesn’t always give clear guidance—and sometimes you have to make reasonable, well-documented decisions in the absence of it.

For AP professionals, preparation, process, and documentation remain the best defense.

Guest: Deborah Richardson
Accounts Payable Consultant, Speaker & Trainer
Host of Putting the AP in Happy

Host: Jason Dinesen
Information Return Intelligence