Form 1042 E-File Waiver Requests: What Withholding Agents Need to Do

If you missed the mid-March deadline to request an e-file waiver for Form 1042, here's what you should do now. The IRS deadline to request an e-file waiver is March 15, or 45 days before your extended due date of September 15 if you filed an extension. Miss it, and you lose the option entirely.

The waiver is not automatic. The IRS requires withholding agents to demonstrate genuine hardship, submit a formally structured written request, and have an authorized officer sign it under penalty of perjury. A vague explanation will not get the job done.

File an extension first. If e-filing Form 1042 is a problem for your organization, the smartest immediate move is to file an extension. That shifts your deadline to September 15 and your waiver request deadline to 45 days before that. It also gives you six months to build an e-filing solution so you don't face the same problem next year.

What the waiver request must contain

The written request must be clearly labeled "Form 1042 e-file Waiver Request" in large letters at the top. From there, the IRS requires four core elements:

• The request must identify the withholding agent by name, federal tax identification number, mailing address, and the specific tax year covered.
• It must describe the steps your organization took to meet the e-filing requirement and explain why those steps failed. Vague references to technical difficulty won't suffice. The IRS wants a concrete account of what was attempted.
• It must document the financial hardship e-filing would create. This means a line-by-line cost comparison: what it costs to paper file versus what it costs to e-file. The difference, the incremental cost, must be detailed in a schedule attached to the request.
• It must explain what steps the organization will take to e-file in future years. The IRS is granting a temporary exemption, not a permanent one.
• An officer authorized to sign the return under IRC section 6062 must sign the request with a specific perjury declaration. If the request comes from an authorized representative rather than the filer directly, a valid Form 2848 must be included. Do not attach the Form 1042 itself, any extension requests, or payments to the waiver submission.

Where and how to submit

Fax is the fastest route: 1-877-477-0575. You can also mail to the IRS Ogden Submission Processing Center, Attn: Form 1042 e-file Waiver Request, Mail Stop 1057, Ogden UT 84201. Delivery services should use 1973 N. Rulon White Blvd., Ogden UT 84404, same mail stop.

One important note on 2025 waivers: The IRS has confirmed it will not issue confirmation letters for tax year 2025. That means if your request is denied, you may not receive formal notice before your filing deadline arrives. Don’t treat silence as approval. Build a contingency, either a path to e-file or a plan to paper file under the assumption the waiver is rejected.

The waiver buys time. An e-filing solution eliminates the problem.