The IRS forwards 1099 data to states. It doesn't file the state return for you, and several states say forwarding isn't enough. Your federal filing can be complete while a state still has nothing from you.
- What CF/SF does
- The IRS forwards. It doesn't file
- Listed in Pub 1220
- 32 jurisdictions, Rev. 5-2026
- Say forwarding isn't enough
- MA, MI, RI, ME, MD, KS
- Left the program
- Oregon, Missouri
- Direct filing, with or without withholding
- MA, MI, RI, ME, OR
- Mostly direct only if tax withheld
- VA, SC, MD, GA (exceptions)
- IRISfile
- Flags MA records. MA file generation in pilot: Pro and above, 1099-NEC and MISC originals, tax years 2025 and 2026, a Pub 1220 file you upload yourself. Files with no state.
What CF/SF does and doesn't do
The Combined Federal/State Filing program (CF/SF) lets you send state data inside your federal filing. Publication 1220 says “the IRS acts as a forwarding agent only. It is the issuer's responsibility to contact the appropriate state(s).”
The program covers 1099-B, DIV, G, INT, K, MISC, NEC, OID, PATR and R, plus Form 5498. Pub 1220 also says each state's requirements are subject to change. A listing in the IRS table means the IRS will forward. It doesn't mean the state is satisfied.
Why CF/SF is not enough
Six states on the IRS list tell filers not to rely on it, in whole or in part.
- Massachusetts
- “Annual reports must be filed directly with DOR even if the transmitter participates in the IRS Combined Federal/State Filing Program (CF/SF).” (Mass.gov)
- Michigan
- “Michigan is not currently receiving copies of 1099 forms filed through the federal IRIS.” Michigan also requires the state copy of a 1099-NEC to go to Treasury directly. (Michigan Treasury)
- Rhode Island
- The informational filing “must be submitted directly with the Division of Taxation.” (ADV 2026-05)
- Maine
- “Do not use the combined Fed/State Program.” (Maine Revenue Services specification)
- Maryland
- “Maryland will NOT be processing any 1099's from the Combined Federal/State Filing Program.” ( Maryland Comptroller)
- Kansas
- Filers “must file all withholding reports directly with the department,” although Kansas participates. (Kansas Department of Revenue FAQ)
Two states have left the program. The revision table in Pub 1220 Rev. 5-2026 says “Removed Oregon as a Combined Federal/State Filing (CF/SF) Program participant,” and Table 1 no longer lists Missouri either (Publication 1220). Oregon says it “is not participating in the Combined Federal/State Filing” (Oregon iWire). Missouri's handbook says separate filing is required (Missouri handbook).
The three patterns
States fall into three groups. The group depends on the form and the trigger as well as on CF/SF, so treat each example as a starting point.
- Direct filing when the state's reporting rules apply
- These states want the return whether or not they withheld tax. Massachusetts requires an annual report of income taxable under Chapter 62 from issuers of 1099-INT, DIV, MISC, NEC, K, R and other 1099 forms (Mass.gov). Michigan wants state copies of any 1099 issued to a Michigan resident, with or without withholding (Michigan Treasury). Rhode Island wants every 1099 type that reports more than $100 (ADV 2026-05). Maine wants payers that are required to e-file 1099s with the IRS to report Maine residents and Maine-sourced payments, regardless of withholding (Maine specification). Oregon wants 1099-NEC, MISC, R, G and K when the recipient, winner or payer has an Oregon address (Oregon iWire).
- Mostly direct filing only when state tax was withheld
- Georgia requires 1099-K and 1099-DA even without withholding. It wants other 1099s, with Form G-1003, when they report Georgia withholding, qualified overtime compensation or qualified cash tips (Georgia employer's tax guide). Virginia “does not require 1099 information if there is no VA income tax withheld” (Virginia upload guide). South Carolina takes statements without its withholding through CF/SF and wants the rest directly (SCDOR RS-1). Maryland wants 1099-MISC and NEC only when Maryland withholding is greater than zero, and still won't process them through CF/SF (Maryland Comptroller).
- CF/SF satisfies the state
- California says that if you file under CF/SF “and the amounts you are reporting to IRS and us are the same, do not file with us,” and the data is forwarded whether it came through FIRE or IRIS (Franchise Tax Board). Idaho is a half case: CF/SF means no 1099 upload, but Form 967 is still required (Idaho State Tax Commission).
Example: one payer, four states
A payer issues a 1099-NEC to a contractor in each state below. The Massachusetts contractor lives in Massachusetts, and the payment is income taxable under Chapter 62. The California return follows CF/SF guidelines, with identical federal and California amounts. The Georgia 1099-NEC reports no withholding, qualified overtime or qualified tips. The Virginia 1099-NEC reports no Virginia withholding. Under those premises, only Massachusetts needs a separate filing.
- Massachusetts
- Report to Massachusetts directly. CF/SF doesn't relieve you (Mass.gov).
- California
- CF/SF covers it if the amounts you report to the IRS and to California match (Franchise Tax Board).
- Georgia
- Nothing to file with Georgia, because the 1099-NEC reports no Georgia withholding, qualified overtime or qualified tips (Georgia guide).
- Virginia
- Nothing to file with Virginia without Virginia withholding (Virginia upload guide).
How to check your state
Answer five questions for every state you file into. Find the answers on the state revenue department's 1099 or withholding page, and check which tax year the page describes before you rely on it.
- 01
Which forms does the state want?
Lists differ. Oregon asks for 1099-NEC, MISC, R, G and K and says 1099-DIV and 1099-INT “are not required” (Oregon iWire). North Carolina requires a 1099-R to a North Carolina address even without withholding, but waives NEC and MISC without North Carolina withholding “until further notice” (NCDOR eNC3 FAQ).
- 02
What triggers the filing?
The trigger is withholding, payee residence, income source or a dollar floor, and states mix them. Rhode Island sets a $100 floor with no withholding test (ADV 2026-05). Missouri asks for a 1099 that is also federally required and reports a Missouri-source payment of $1,200 or more. It excludes wages already subject to Missouri withholding and income already on an S-corp or partnership information report (Missouri handbook).
- 03
Which file format does it accept?
Kansas takes web forms, a CSV, or a Pub 1220 file (K-99CSV, K-99MT). Alabama reads withholding data in an EFW2 layout, not Pub 1220 (Alabama Form 10).
- 04
Who may upload, and where?
Oregon lets a third-party business submit through its own account, and an individual third party submit through the client (Oregon iWire). Maryland asks a payroll provider or third party to register as a Transmitter user first (Maryland Comptroller).
- 05
Which reconciliation form goes with it?
Maryland generates Form MW508 automatically when you bulk upload (Maryland Comptroller). North Carolina allows Form NC-3 and the statements to go in separate submissions (NCDOR eNC3 FAQ).
Format changes for 2027
Pub 1220 is a FIRE specification. States that built on it are now deciding what replaces it, and they're deciding differently.
- North Carolina
- Plans XML filing in January 2027 and says it will stop supporting Pub 1220 then. File specifications weren't posted in early October 2026. (NCDOR eNC3 FAQ)
- Montana
- A June 2026 notice announces IRIS XML only and says Pub 1220 files will not be accepted. It gives no implementation date. (Montana Department of Revenue)
- Georgia
- Will use the IRS IRIS schemas for tax year 2026 after FIRE retires. (Georgia employer's tax guide)
- Idaho
- Drops the TXT upload for 2026 returns filed in 2027, in favor of CSV or XML upload. (Idaho State Tax Commission)
- Maine
- Expects to conform to the IRS XML format beginning with forms issued for tax year 2026. (Maine specification)
- Maryland
- Says bulk XML filing “will be available” for the tax year 2026 filing season. (Maryland Comptroller)
- Massachusetts
- Intends to accept an IRIS-based layout beginning in 2027. No layout is published, so Pub 1220 stays the working format. (Mass.gov bulk filing FAQ)
- Missouri
- Says it “does not support” IRIS XML and wants fixed-format text files. (Missouri handbook)
A file that works for one state can fail in the next. Recheck each state's specification before you build a file, and again close to the filing season.
What IRISfile does for state filing
IRISfile flags each record that owes Massachusetts an annual 1099 report. It marks the status unknown when a payer or payee state is missing.
Massachusetts file generation is in pilot. It runs on the Pro plan and above, for 1099-NEC and MISC originals, tax years 2025 and 2026. It builds a Pub 1220 file. You upload that file to MassTaxConnect yourself, because IRISfile doesn't upload it. IRISfile files with no state.
IRISfile doesn't file with any state, and it doesn't check any other state yet. See the plans and pricing for what each tier includes. For federal dates, use the 1099 deadlines guide.
Questions
- Does the Combined Federal/State Filing program file my state 1099s?
- No. The IRS forwards covered 1099 data to participating states. Pub 1220 says the IRS acts as a forwarding agent only, and that contacting the state is the issuer's responsibility.
- Which states don't accept CF/SF even though the IRS lists them?
- Massachusetts, Michigan, Rhode Island, Maine, Maryland and Kansas each say forwarding doesn't meet their rules in whole or in part. Oregon and Missouri no longer participate in the program.
- Do I file a state 1099 if no state tax was withheld?
- It depends on the state. Massachusetts, Michigan, Rhode Island, Maine and Oregon want filings with or without withholding, within their own rules. Virginia, South Carolina and Maryland want them mostly when state tax was withheld. Georgia wants 1099-K and 1099-DA regardless, and other forms mainly with withholding.
- Is Oregon a Combined Federal/State Filing state?
- No. Pub 1220 Rev. 5-2026 removed Oregon from the program, and Oregon's revenue department says it isn't participating. File directly through Oregon iWire.
- Will state filing formats change for 2027?
- Several states have said so. North Carolina plans XML filing in January 2027 and drops Pub 1220. Montana has announced IRIS XML only, with no date yet. Georgia uses IRIS schemas for tax year 2026. Check each state's current specification before you file.
- Does IRISfile file state 1099s?
- No. IRISfile doesn't file with any state. It flags each record that owes Massachusetts an annual 1099 report. Massachusetts file generation is in pilot: Pro plan and above, 1099-NEC and MISC originals, tax years 2025 and 2026, a Pub 1220 file you upload to MassTaxConnect yourself. IRISfile files with no state, and no other state is checked.