What Is Form 948 and When Do You Need to File It?

Form 948 is used for specific tax-related filings, and knowing when it applies helps businesses avoid compliance issues. Many employers may not encounter this form until required to submit it, making it essential to understand its purpose and filing requirements. Filing the correct forms on time ensures compliance with IRS regulations and prevents penalties.

Reason for Filing

Form 948 authorizes a third party to file and deposit employment taxes on behalf of an employer. This allows a payroll service provider or reporting agent to manage tax obligations, including Forms 941 (Employer’s Quarterly Federal Tax Return) and 940 (Employer’s Annual Federal Unemployment Tax Return).

The IRS requires this form to ensure only authorized parties handle payroll tax filings. Without it, the employer remains fully responsible for errors or missed payments, even if a third party was involved. Businesses that frequently change payroll providers or use multiple agents may need to file this form more than once to keep IRS records current.

Key Filing Requirements

Employers must meet IRS conditions when submitting Form 948. It is required for any business that designates a reporting agent to handle employment tax filings, regardless of size. The employer’s legal name, Employer Identification Number (EIN), and the reporting agent’s details must be accurately provided.

The form should be filed as soon as an employer engages a reporting agent to avoid gaps in tax reporting. While there is no direct penalty for late submission, failing to authorize an agent can lead to missed or incorrect filings, resulting in penalties under Internal Revenue Code 6656. These penalties start at 2% of the unpaid amount and increase up to 15%, depending on the delay.

Employers should retain supporting documentation, such as contracts with the reporting agent, to verify the authorization. If discrepancies arise, the IRS may request proof that the employer intended to delegate tax responsibilities. In some cases, a written statement may be required to confirm the authorization’s validity, particularly in disputes over tax filings.

Instructions for Completion

Accuracy is critical when completing Form 948 to ensure the IRS properly records the reporting agent’s authorization. The form begins with the employer’s identifying information, including the official business name and EIN. Any discrepancies with IRS records can delay processing or result in rejection. Employers should ensure the information matches IRS records exactly.

Next, the form requires details about the reporting agent, including their legal name, EIN, and contact information. If the agent operates under multiple EINs, the correct one must be used to prevent misattribution of tax filings. The agent must also be recognized by the IRS as an authorized entity to file employment taxes, which typically requires completing Form 8655 (Reporting Agent Authorization).

Employers must specify which tax periods and filings the agent will handle. They should select the appropriate boxes to indicate whether the agent will submit quarterly or annual payroll tax returns. If an employer wants the agent to handle only certain filings while retaining responsibility for others, these limitations should be clearly marked. Leaving this section incomplete may result in broader authorization than intended.

The final step requires signatures from both the employer and an authorized representative of the reporting agent. Only individuals with legal authority—such as corporate officers, sole proprietors, or partners—may sign. If an unauthorized person signs, the form may be invalid. The completed form should be submitted to the appropriate IRS processing center, which varies based on the employer’s location. Employers can check IRS instructions or contact their local IRS office for the correct mailing address.

Possible Exemptions

Some businesses do not need to file Form 948, depending on their payroll structure. Companies that handle payroll tax filings internally without using a third-party agent do not require this form. Sole proprietors with no employees generally do not need to file unless they later hire workers and outsource payroll.

Nonprofits under Internal Revenue Code 501(c)(3) may also be exempt if they process payroll in-house. However, if they use an external payroll provider, Form 948 is required. Government agencies often have separate payroll reporting systems and may not need to file this form.

Impact on Other Financial Duties

Authorizing a reporting agent through Form 948 shifts payroll tax responsibilities but does not eliminate the employer’s legal liability. Employers must still monitor filings to ensure accuracy. Regular reconciliation of payroll records with IRS transcripts can help identify discrepancies before they lead to penalties.

Employers should also consider how this authorization affects their access to the Electronic Federal Tax Payment System (EFTPS). If a reporting agent is authorized to make deposits, the employer may lose direct access unless explicitly retained. This can create challenges if adjustments or corrections are needed outside the agent’s scope.

Businesses claiming tax credits, such as the Work Opportunity Tax Credit (WOTC) or Employee Retention Credit (ERC), must ensure the reporting agent correctly applies these credits when filing payroll tax returns. Errors in credit application can delay refunds or trigger IRS audits, making communication with the agent essential.

Retention of Records

Employers must keep copies of Form 948 and any IRS correspondence confirming its acceptance for at least four years, as required under IRS guidelines for employment tax documentation. These records help verify the reporting agent’s authorization if disputes arise.

Payroll records, tax deposit confirmations, and agreements with the reporting agent should also be retained. If the IRS audits the business or requests verification of tax filings, having organized records can expedite resolution. Employers that switch reporting agents should keep documentation for all prior agents to maintain a complete tax reporting history. If an agent is terminated or replaced, the IRS should be notified promptly to prevent unauthorized filings under a previous authorization.

Where to Request Forms and Assistance

Employers can obtain Form 948 from the IRS website, where the most recent version is available for download. The IRS periodically updates tax forms, so businesses should ensure they are using the latest edition. Printed copies can also be requested by calling the IRS or visiting a local Taxpayer Assistance Center.

For assistance with completing and filing the form, businesses can consult a tax professional, payroll service provider, or the IRS Business and Specialty Tax Line. Employers with complex payroll structures or multiple reporting agents may benefit from professional guidance to ensure compliance. The IRS also provides Publication 15 (Employer’s Tax Guide), which outlines payroll tax responsibilities and explains how Form 948 fits into broader tax obligations.