The IRS has published a new draft Form W-9 (Rev. June 2026), less than two years after the significant March 2024 revision. While the 2024 update introduced new disclosure requirements for flow-through entities and clarified rules for disregarded entities, the 2026 draft signals the IRS’s continued push to adapt documentation to evolving tax reporting, especially in the digital asset space.
The draft form doesn’t overhaul the structure but introduces two material changes and one important clarification. Here’s what you need to know.
*Update (June 2026): This article references the January 2026 draft of Form W-9. The IRS has since issued a revised draft (Rev. June 2026), and certain requirements may have changed. Please refer to the latest version for current guidance.
Key Takeaways: IRS Draft Form W-9 (2026)
The IRS released an updated draft of Form W-9 in June 2026, following an earlier January 2026 draft. The proposed revisions address digital asset broker reporting, taxpayer identification number (TIN) requirements, and certification language, with potential implications for financial institutions, withholding agents, and businesses collecting Forms W-9.
Key points:
- Digital asset reporting: Updated certification language addresses requirements relevant to digital asset brokers.
- TIN clarification: Revised instructions clarify taxpayer identification requirements for sole proprietors and disregarded entities.
- Compliance impact: Organizations may need to review their W-9 collection processes, substitute forms, and automated tax documentation systems.
- Implementation status: The June 2026 version remains a draft. Organizations should monitor IRS updates before implementing changes.
Bottom line: Businesses should review the proposed changes now to prepare their tax documentation and onboarding processes while awaiting final IRS guidance
What Changed for Digital Asset Brokers in the 2026 Draft Form W-9?
- A new checkbox certification has been added in Part II of the form.
- “I am exempt from information reporting as a U.S. digital asset broker within the meaning of Regulations section 1.6045-1(g)(4)(i) (A)(1) (other than a registered investment adviser). I claim exempt status under Regulations section 1.6045-1(c)(3)(i)(B)(12).”
- New exempt payee code (14) has been added: U.S. digital asset brokers (other than registered investment advisers) may now certify that they are exempt from information reporting under Reg. §1.6045-1.
- 14—A payee in a transaction involving digital assets exempt from backup withholding under Notice 2025-33 through calendar year 2026. For later years, see Regulations section 31.3406(b)(3)-2.
Why this matters? This new certification aligns the Form W-9 with the rollout of Form 1099-DA, the new information return for digital asset transactions; however, with the addition of the new certification checkbox, any substitute W-9s will require updating, regardless of whether digital asset payments apply.
What TIN Must Sole Proprietors and Disregarded Entities Provide?
- The draft form explicitly states: “Do not report the employer identification number (EIN) of a sole proprietorship or disregarded entity.”
- Instead, a sole proprietor must provide an SSN, and a disregarded entity must provide the owner’s TIN (EIN for entities; SSN for individuals/sole proprietors).
This clarification could create a change in circumstance for any customer that previously submitted a Form W-9 as a sole proprietor and used an EIN. Organizations should be prepared to identify, remediate, and re-collect forms where necessary, otherwise this can have downstream impacts (think IRS name/TIN mismatches and B-Notices).
What Should Financial Institutions Do to Prepare?
For financial institutions, withholding agents, and digital asset platforms, the changes are a compliance signal.
- Digital asset reporting is mainstream. The IRS is weaving crypto into legacy documentation, and Form W-9 now explicitly anticipates broker exemptions.
- TIN collection must be airtight. Sole proprietors and disregarded entities misreporting EINs instead of owner SSNs/TINs will create mismatches and result in incorrect reporting and B-Notices. The draft makes the rule impossible to miss.
- Onboarding processes must adapt. Organizations should be prepared to collect the new Form W-9 within the appropriate timelines, update substitute forms for the new certification (regardless of payment type) and update any validation requirements.
The draft Form W-9 (Rev. June 2026) is another reminder that tax documentation is not static. With digital assets entering the mainstream of IRS reporting and heightened scrutiny on entity classification and TIN matching, organizations should review their onboarding workflows, update validation controls, and communicate proactively with clients and partners.
At Comply Exchange, we’re continuously enhancing our solutions to automate form validation, enforce the correct TIN logic, and adapt seamlessly to IRS revisions. If you’re ready to make tax compliance onboarding simple, not stressful, we can help.
Frequently Asked Questions About the 2026 IRS Draft Form W-9
The IRS released a revised draft Form W-9 in June 2026, following an earlier January 2026 draft. The proposed updates address digital asset broker certification, taxpayer identification number (TIN) requirements, and related instructions. These changes could affect how financial institutions, withholding agents, and businesses collect and validate taxpayer information for US tax reporting.
The June 2026 Form W-9 was released as a draft and should not be treated as the final version until the IRS formally publishes it. Organizations should continue using the applicable official IRS form and monitor further updates before making changes to their W-9 collection and certification procedures.
The 2026 draft Form W-9 includes proposed certification changes relevant to digital asset brokers. These updates reflect evolving US tax reporting requirements for digital asset transactions. Brokers and financial institutions involved in digital asset reporting should review the proposed certification language and assess whether their taxpayer onboarding and documentation processes will require changes.
Article Updated: October 2026
