The 1099 threshold for research participant payments depends on the year you make each payment. Under IRS Revenue Procedure 2026-35, issued November 5, 2026, payments made in 2027 to non-employee participants are reported once one payer’s total reaches $2,100. For payments made in 2026, the line is $2,000.
That leaves study teams two jobs before January: close out 2026 payment logs and fix consent forms that name “$2,000.” These figures are the federal rule, not tax advice. Your controller, accounts payable office, or IRB sets how your institution tracks, collects, and files.
The threshold follows the year you make the payment, not the year you file. For non-employee participants, it’s $2,100 for payments made in 2027. It applies to one payer’s total to one participant over the calendar year.
| Payments made in | Reporting threshold | IRS source |
|---|---|---|
| 2025 | $600 | Publication 1099 for 2026, which gives $600 as the previous amount |
| 2026 | $2,000 | Instructions for Forms 1099-MISC and 1099-NEC, December 2026 revision |
| 2027 | $2,100 | Revenue Procedure 2026-35, section 3.52 |
Section 3.52 of Revenue Procedure 2026-35 puts the 2027 figure in one sentence. It reads: “For payments made in calendar year 2027, the reporting threshold for payments described in § 6041(a) is $2,100.” It came with the other 2027 inflation adjustments in the IRS’s November 5, 2026 news release.
The forms you send in early 2027 still use $2,000. The IRS’s December 2026 Instructions for Forms 1099-MISC and 1099-NEC say to use that revision “to file 2026 information with the IRS in early 2027.” So the $2,100 line first shows up on the forms for 2027 payments, filed in early 2028.
For a medical research study, the IRS lists participant payments under Form 1099-MISC, Box 3, “Other income.” Its December 2026 instructions name them in one line of the Box 3 list. It reads “A payment or series of payments made to individuals for participating in a medical research study or studies.”
That IRS line names medical research only. For surveys, user interviews, and focus groups, your controller decides how the payment is classified. Penn State’s HRPP, in March 2026, applies Form 1099 (Miscellaneous Income) reporting to all Penn State research studies, not only medical ones.
Two limits come with the threshold. First, it decides who gets a form. It doesn’t change what’s taxable. NIH’s January 2026 participant information sheet says payment for taking part in research “may be considered taxable income.”
Second, employees who take part in a study are a separate case. Duke’s IRB notice from December 2025 states the $2,000 rule for payments to non-employees of Duke University. Ask payroll how your institution handles employee participants. For other non-employees, such as contractors, our guide to how gift cards are taxed walks through the rules.
Participants outside the US need different paperwork. IRS Publication 1099 for 2026 suggests a Form W-8 for a foreign recipient instead of a W-9. Route those payments to your controller before you pay, and ask about your state’s reporting rules at the same time.
Closing out 2026 takes five steps, and each one uses the $2,000 line. Finish them before participant copies of 2026 Forms 1099-MISC are due. The IRS due dates follow the steps.
The December 2026 instructions set three IRS dates for 2026 Forms 1099-MISC. A weekend due date moves to the next business day, and two of the three land on a Sunday in 2027.
Check the e-filing rule, too. The same instructions require e-filing once your institution files 10 or more information returns of any type in total, a limit set by T.D. 9972 in 2023.
See what an IRB checks in the amount, method, and timing of participant payments.
Read the Guide →Consent forms that name the threshold without a dollar figure survive each yearly change. A form that says “$2,000” goes stale when 2027 payments start at $2,100 under Revenue Procedure 2026-35. Penn State’s HRPP wrote its March 2026 language to be “broadly applicable” for exactly that reason.
The first pattern names a figure, as the Sterling IRB template from February 2026 does. It reads, “If you receive more than $2,000.00 in one calendar year from participating in a clinical research study, you will receive a 1099 tax form the following January.” It then warns participants that the reportable amount can change each year.
The second pattern names no figure, as in the Johns Hopkins IRB’s May 2026 update. Its templates for studies submitted on or after September 8, 2026 tie the 1099-MISC to “the IRS reporting threshold per year.” Johns Hopkins reports a participant once “your total payments from Johns Hopkins exceed” that threshold.
Whichever pattern you use, check the verb. The IRS’s December 2026 instructions report Box 3 income “of $2,000 or more.” Wording like “more than” or “exceed” leaves out a participant paid exactly the threshold.
Example to adapt with your IRB, built on the no-figure pattern: “Payments for taking part in research may be considered taxable income. If your total payments from [Institution] reach that year’s IRS reporting threshold, [Institution] reports them on Form 1099-MISC and sends you a copy.”
Enrolled participants don’t need a new consent for this change alone at Penn State or the University of Michigan. Penn State’s HRPP uses an information sheet or verbal notice, then updates the form at the next modification. The University of Michigan HRPP’s October 2026 FAQ uses a “Dear Research Participant” letter until the IRB approves an updated form.
The IRS threshold decides who gets a 1099. Your institution’s trigger decides when you collect an SSN or W-9. At the four institutions below, it sits under the IRS’s $2,000 line for 2026.
The University of Rochester’s research subject payments policy, as of November 2026, also covers participants in more than one study. It lets accounts payable ask a department for a W-9 when a subject is in several studies or receives other payments during the year.
| Institution and source | Internal trigger | What it requires |
|---|---|---|
| Johns Hopkins IRB, May 2026 update | $200 per person per calendar year | Gift cards or petty cash without an SSN or ITIN only up to $200 |
| VCU HRPP, January 2026 update | Study payments over $250 | Track payments and collect the SSN; the previous trigger was $50 |
| University of Rochester policy, as of November 2026 | $1,500 or more per calendar year, per protocol | The principal investigator collects a completed W-9 |
| University of Michigan HRPP, October 2026 FAQ | More than $1,600 per participant per calendar year, from November 7, 2026 | Collect the SSN; the previous trigger was more than $400 |
So build your log around two numbers: your institution’s collection trigger and the IRS reporting threshold for the payment year. Flag a participant at the lower one, and you’ll have the paperwork before the IRS line matters.
Keep the dollar figure in your payment log and the rule in your consent form. Finish 2026 at the IRS’s $2,000 line from its December 2026 instructions, then set the 2027 flag to $2,100 from Revenue Procedure 2026-35.
For next year’s method and reward, see our guides to paying research participants digitally and choosing survey incentives. Then confirm both numbers and your cutoff with your controller before January, and your 2027 payments are ready to go.
Send gift cards by email, text, or reward link, and let participants choose from 4,300+ brands.
See the Use Case →They can be, since the $2,000 threshold only decides who gets a 1099. NIH’s January 2026 participant information sheet says payment for taking part in research “may be considered taxable income.” It sends tax questions to a qualified tax professional.
No, the forms sent in early 2027 report 2026 payments, so they use $2,000. Revenue Procedure 2026-35 sets $2,100 “for payments made in calendar year 2027,” so it first applies to the 1099-MISC forms sent in early 2028.
Not for the threshold change alone at Penn State or the University of Michigan. Both give enrolled participants an information sheet, a verbal notice, or a letter, then update the consent form at the next amendment or review. Your own IRB sets the rule for your studies.
At Johns Hopkins, the IRB groups gift cards with petty cash as cash equivalents. It pays them without an SSN only up to $200 per person per year. Ask your controller how your institution totals them, including cards sent in late December.
No, not when they repay reasonable out-of-pocket expenses. NIH’s January 2026 participant information sheet says reimbursement for costs such as parking, meals, or mileage “is not included in calculating the $2,000 threshold.” Keep the receipts with the payment log.