HOA 1099 Requirements for 2026: The New $2,000 Threshold

Quick answer: Yes, an HOA has to issue Form 1099-NEC to vendors it pays for services in the course of running the association, because the IRS treats nonprofit organizations as engaged in a trade or business. Starting with payments made in 2026, the reporting threshold rose from $600 to $2,000 per vendor for the year, and it may be adjusted for inflation beginning in 2027. Payments to corporations, payments for merchandise, and payments made by credit card are generally excluded, but attorneys must get a 1099 even if they are incorporated. The 2026 forms are due to the IRS and to vendors by February 1, 2027, because January 31 falls on a Sunday.

Most self-managed HOAs pay a handful of independent contractors every year: a landscaper, a pool service, a handyman, a bookkeeper, an attorney. Each one is a possible 1099. This guide covers what changed for 2026, which vendors need a form, and a year-end routine a volunteer treasurer can actually follow.

What changed for 2026: the $2,000 threshold

For years the trigger was $600. The law changed, and the IRS instructions for the December 2026 revision of Forms 1099-MISC and 1099-NEC say:

For tax years beginning after 2025, the minimum threshold amount for reporting certain payments required to be reported on certain information returns and/or perform backup withholding on those payments increased to $2,000 and may be adjusted for inflation beginning in calendar year 2027.

In practice, for HOAs:

The higher threshold will take many small vendors off your list. A handyman you paid $1,400 in 2026 no longer needs a 1099-NEC. A landscaper you paid $9,000 still does, unless the landscaper is a corporation.

Does an HOA need to file 1099s at all?

Yes. The instructions limit reporting to payments made in the course of a trade or business, and then say:

You are engaged in a trade or business if you operate for gain or profit. However, nonprofit organizations are considered to be engaged in a trade or business and are subject to these reporting requirements.

So a homeowners’ or condominium association, whether it files Form 1120-H or Form 1120, is in the same position as any other payer. Personal payments by board members out of their own pockets are not the association’s to report.

Which payments go on Form 1099-NEC

File Form 1099-NEC, Nonemployee Compensation, for each person in the course of your business during the year to whom you have paid at least $2,000 in: Services performed by someone who is not your employee (including parts and materials) ( box 1a ); or Payments to an attorney ( box 1a ).

Note the words including parts and materials. If your plumber’s invoice is $1,500 labor plus $800 parts, the full $2,300 counts toward the threshold.

Common HOA vendors and whether they usually get a 1099-NEC

The table is a starting point. The vendor’s Form W-9 decides it, so collect one from every vendor before the first payment.

The exceptions, in the IRS’s words

Payments to corporations are generally exempt, including an LLC that is treated as a C or S corporation, but attorneys are the big exception:

The exemption from reporting payments made to corporations does not apply to payments for legal services. Therefore, you must report attorneys’ fees (in box 1a of Form 1099-NEC) or gross proceeds (in box 10 of Form 1099-MISC), as described earlier, to corporations that provide legal services.

Payments for merchandise, telephone, freight, storage and similar items are also excluded. Card and payment-app payments are excluded because someone else reports them:

Payments made with a credit card or payment card and certain other types of payments, including third-party network transactions, must be reported on Form 1099-K by the payment settlement entity under section 6050W and are not subject to reporting on Form 1099-MISC or Form 1099-NEC.

If your association pays some vendors by check and others by card, only the check, ACH or cash payments count toward that vendor’s $2,000.

Directors’ fees are rare in self-managed HOAs, but if your association pays them, they are reportable:

You must report directors’ fees and other remuneration, including payments made after retirement, on Form 1099-NEC in the year paid.

Ordinary reimbursements of a volunteer’s out-of-pocket expenses are a different question; confirm the treatment with your tax preparer.

Deadlines and how to file

Section 6071© requires you to file Form 1099-NEC on or before January 31, using either paper or electronic filing procedures.

Copies to the vendor are due on the same date. The instructions also say:

If any date shown falls on a Saturday, Sunday, or legal holiday in the District of Columbia or where the return is to be filed, the due date is the next business day.

January 31, 2027 is a Sunday, so 2026 Forms 1099-NEC are due Monday, February 1, 2027.

On e-filing:

T.D. 9972, published February 23, 2023, lowered the e-file threshold to 10 (calculated by aggregating all information returns), effective for information returns required to be filed on or after January 1, 2024.

The 10 counts all of your information returns together. An HOA filing 10 or more 1099s (plus any W-2s) has to e-file. The IRS’s Information Returns Intake System (IRIS) is one option for small batches.

State copies

Many states want their own copy of a 1099-NEC, and the rules differ. This is a federal post, so treat the table below as a prompt to check, not a final answer:

For state-specific finance rules, our sister site Dynamite Management covers state HOA law in depth.

A year-end 1099 routine for treasurers

1. Collect a W-9 before the first payment to any new vendor. File it with the vendor record.
2. Mark each vendor in your accounting system as 1099-eligible or not, based on the W-9 tax classification.
3. Pay by check or ACH where you can, so your records match what you report. Card payments drop out of the 1099 count.
4. In early January, run a vendor payment report for the calendar year, filtered to 1099-eligible vendors at $2,000 or more (for 2026 payments).
5. Add parts and materials billed by service vendors. They count.
6. File and send by the deadline, then keep copies with the year’s tax file, next to your Form 1120-H workpapers.

If your software tracks 1099 status per vendor, step 4 takes a minute. See the best HOA accounting software for self-managed associations for which tools do this, and how to self-manage an HOA for the rest of the treasurer’s year.

How this fits with your HOA tax return

Form 1099s are separate from the association’s own income tax return. Most HOAs file Form 1120-H; our Form 1120-H instructions walk through it. Clean vendor records make both filings easier, and they also feed the year-end HOA financial statements owners will see. Dynamite Management prepares Form 1120-H for a flat $175 per association, plus $100 for a state return in any state.

Everything above comes from the IRS Instructions for Forms 1099-MISC and 1099-NEC (Rev. December 2026). Thresholds can change by later legislation or inflation adjustments, so confirm with the current instructions and your tax adviser before filing.

This is not legal or tax advice.

Keep 1099s simple with HOA Fiscal

HOA Fiscal is built for fully self-managed associations: vendor records, payments, budgets and an owner portal in one place, so the January 1099 report is ready when you need it. Try HOA Fiscal, and if you’d rather hand off the financial side while still self-managing everything else, your association can upgrade to Dynamite Management.

FAQ

Does an HOA have to issue 1099s? Yes. The IRS treats nonprofit organizations as engaged in a trade or business, so an HOA must issue Form 1099-NEC to non-corporate vendors it pays for services above the threshold.

What is the 1099-NEC threshold for 2026? $2,000 per vendor for the year, up from $600. It applies to tax years beginning after 2025 and may be adjusted for inflation beginning in 2027.

Does an HOA need to send a 1099 to its attorney? Yes. Payments for legal services are reportable even when the law firm is a corporation.

When are 2026 Forms 1099-NEC due? February 1, 2027, to both the IRS and the vendor, because January 31, 2027 falls on a Sunday.

Do payments made by credit card count? No. Card and payment-app payments are reported by the payment processor on Form 1099-K, not on Form 1099-NEC.

Cover: Photo by Joel Hägele on Pexels