Compliance
Understanding U.S. Compliance Changes: Form 1099-K, ERC, and PTIN in the One, Big, Beautiful Bill
A wave of compliance updates under the One, Big, Beautiful Bill affects third-party payment thresholds, tax preparer ID rules, and recovery of credits—what businesses and tax professionals need to prioritize now.
By NomadicTax Research Team • 5-8 min read • November 21, 2025
## What’s Changed Under the One, Big, Beautiful Bill (OBBB)
Since enactment, the OBBB has triggered several IRS actions to enforce updated compliance obligations:
- **1099-K Threshold Reverts**: The reporting threshold for third-party payment processors returned to **$20,000**, down from higher levels, affecting platforms and merchants. The IRS issued FAQs in *Fact Sheet 2025-08* to clarify new reporting obligations. ([irs.gov](https://www.irs.gov/newsroom/news-releases-for-october-2025?utm_source=openai))
- **ERC (“Employee Retention Credit”) Limitations**: For credits or refunds claimed for Q3 and Q4 2021 but filed late (after January 31, 2024), the OBBB limits eligibility or refunds; FAQs issued in *Fact Sheet 2025-07*. ([irs.gov](https://www.irs.gov/newsroom/news-releases-for-october-2025?utm_source=openai))
- **PTIN Renewal Fee and Rule Change**: All tax preparers must renew PTINs annually; IRS has changed fee structure to $10 plus contractor costs under proposed regulation. Maintaining valid PTINs is essential for any person preparing returns for compensation. ([irs.gov](https://www.irs.gov/irb/2025-42_IRB?utm_source=openai))
## Compliance Action Plan for Businesses and Practitioners
- **Merchants and Marketplaces**: Review platform payouts; reconcile with Form 1099-K filings. If aggregates reach $20,000 via third-party platforms, reporting kicks in.
- **Credit Claims (ERC)**: If planning to claim or assert refund of ERC, check whether the date of filing is before the OBBB cutoff. Review whether documentation satisfies “timeliness” provisions.
- **Tax Preparers & Firms**: Renew PTIN as required. Ensure user fees are accounted for in your budgeting. Maintain rigorous records of billing for each return you prepare.
- **Update Internal Controls**: Verify all employees or contractors who prepare returns are properly registered. Use checklists to ensure compliance thresholds are met or not exceeded.
## Practical Examples
- **Marketplace Seller**: If you sell on multiple platforms, scan all income from each. Under the reverted 1099-K threshold, earning $21,000 via a single platform will trigger reporting. Without awareness, potential non-compliance.
- **Small Accounting Firm**: Two preparers must renew PTINs. One pays new $10 base fee plus contractor portion; failure to renew invalidates returns you submit.
- **Business Claiming ERC**: A company filed a claim for Q4 2021 after the Jan 31, 2024 deadline. Under FAQs, most of that claim may now be disallowed; need to assess exposure.
## Compliance Reminders
- **Deadlines** matter: Many of these rules have filing cutoffs and pivotal dates. Check dates in your specific case.
- **Record Evidence**: Documentation, communications, ledger entries all help in case of IRS audits.
- **Stay Updated**: IRS FAQ releases and notices may change guidance—subscribe or follow updates.
## Bottom Line
The One, Big, Beautiful Bill has introduced important thresholds and procedural changes. Being proactive—especially for 1099-K obligations, tax preparer compliance, and credit claims—can prevent costly missteps and audits in the coming tax seasons.