Getting an EFIN to e-file Form 1042: the three IRS routes, including the one for a responsible official with an ITIN and the foreign EFIN

Who must e-file Form 1042

“Electronic filing of Form 1042 is required for a withholding agent that is a financial institution. Additionally, electronic filing of Form 1042 is required for withholding agents that are required to file 10 or more information returns, as described in Regulations section 301.6011-2, during the year or that is a partnership with more than 100 partners” (2025 Instructions for Form 1042). The 10-return count aggregates all information returns of every type (Forms 1042-S, 1099, W-2 and the rest), so almost any withholding agent large enough to file a Form 1042 is over it. The requirement comes from the February 2023 regulations (T.D. 9972) and applied first to the Form 1042 due March 15, 2024. The IRS then granted relief: Notice 2024-26 exempted all withholding agents from e-filing Forms 1042 required to be filed in 2024, and foreign withholding agents for 2025 as well. Those years are over. For the Form 1042 due March 16, 2026 and after, a foreign withholding agent with 10 or more information returns is expected to e-file, and the only remaining relief is a Form 8508 waiver for undue hardship, granted case by case.

Paper remains the route only for a withholding agent under the 10-return count that is not a financial institution: “Mail Form 1042 by the 15th day of the 3rd month after the end of the calendar year (March 15)” to Ogden.

What an EFIN is, and what it is not

An EFIN identifies the firm that originates an electronic submission to the IRS. It is issued through the IRS e-file application in e-Services, after the firm’s principals and responsible officials are identified and, for most provider types, pass suitability checks. It is not a Transmitter Control Code (the TCC is for FIRE and IRIS, where the Forms 1042-S go; see the TCC guide), and it is not an account for the IRS systems themselves: Form 1042 is sent through MeF by software that has passed Assurance Testing, or by a transmitter, under the EFIN of the firm that originates it. A withholding agent that uses an outside preparer or an Authorized IRS e-file Provider to file its Form 1042 does not need its own EFIN at all; the provider’s EFIN is on the return.

The IRS’s own definition of the option most Form 1042 filers use: “A Large Taxpayer is a Provider Option on the IRS e-file Application, but it is not an Authorized IRS e-file Provider. A Large Taxpayer is a business or other entity with assets of $10 million or more, or a partnership with more than 100 partners, that originates the electronic submission of its own return(s)” (tutorial for filers with an ITIN). The tutorials direct Form 1042 filers to that option whether or not they meet the asset figure; it is the IRS’s chosen path for a withholding agent filing its own return.

The three routes

The three tutorials share most of their text and screens: “The Provider must submit an IRS e-file application to obtain an EFIN. The Provider must include its firm information including Employer Identification Number (EIN), address, and phone number.” They differ in the provider option chosen and in who can sign.

Route 1: a responsible official with an ITIN

“Providers may obtain an Electronic Filing Identification Number (EFIN) for use by a firm if the authorized representative (Responsible Official) has an Individual Taxpayer Identification Number (ITIN).” The provider “must select ‘Large Taxpayer’ as the Provider Option and then select Form 1042 by choosing the first radio button. The Authorized Users will be the Responsible Official(s) with an Individual Taxpayer Identification Number (ITIN). The Primary Contact may be the same as the Responsible Official.” The limit is explicit: “When adding a Responsible Official with an Individual Taxpayer Identification Number (ITIN), then you must have a Provider Option of Large Taxpayer and only Forms 1042 and 1120F selected. Choose only the first radio button.” An ITIN holder cannot be the responsible official for an EFIN that files other returns; the EFIN is for the foreign entity’s own Form 1042 (and Form 1120-F).

Route 2: a responsible official with an SSN

When the responsible official has an SSN, the tutorial’s path is different and, read literally, odd: “The provider must select ‘Electronic Return Originator’ as the Provider Option and then select ‘Not for Profit’ as the Service Type and select ‘Large Taxpayer’ as the Type of Business Activity and then select Form 1042.” “Not for Profit” here is a service type on the application, not a statement about the firm’s tax status; the tutorials note that “Firms that will be selecting Not for Profit do not need to add Principal or Principal Consent,” which is why the IRS routes this case through it: the application can be completed by the responsible official alone. The authorized users are “the Responsible Official(s) with a Social Security Number (SSN)” and the primary contact may be the same person.

Route 3: the foreign EFIN

“Providers may obtain an Electronic Filing Identification Number (EFIN) for use by a firm in ‘its business-related group’ if the firm can’t obtain an EFIN because its Principals and/or Responsible Officials are not U.S. citizens or aliens lawfully admitted for permanent residence as described in 8 USC 1101(a)(20). The term ‘business-related group’ applies to brother-sister firms, subsidiaries, franchises, affiliates, etc. ‘Business-related group’ is broad to include any business relationship.” So a U.S. affiliate, parent, franchisor, or any U.S. firm with a business relationship that is itself an Authorized IRS e-file Provider can hold an EFIN for the foreign withholding agent’s location. The mechanics: “The Provider must submit an IRS e-file application for each foreign EFIN it wants to obtain. The Provider must include its address as the mailing address but include the physical address of the firm for which it is obtaining the foreign EFIN. The IRS will issue EFINs to the Provider for each location from which the firm in its ‘business-related group’ will originate the electronic submission of returns.”

The responsibility sits with the U.S. provider: “The Provider is responsible for the business-related firm’s adherence to IRS e-file rules but is not responsible for the preparation of returns of the firm in its ‘business-related group.’ The Provider should only obtain EFINs for other firms it knows to be trustworthy.” The IRS “may inactivate the EFIN for a ‘business-related’ firm that is not adhering to IRS e-file rules without sanctioning the Provider or affecting its other EFINs,” and the provider “may delete the EFIN assigned to any firm location when it determines appropriate.” The IRS’s Q&A page on the rule (reviewed August 6, 2026) adds that the provider sets “its own policies to determine the firms for which it will obtain an EFIN and how it monitors the use of the EFIN.”

The application, screen by screen

All three tutorials walk the same path: “Access Tax Pros from irs.gov. Select Access e-Services. Select Access e-file services. Select Access e-file application. Sign In or Create a New Account.” Then, in order:

1. Firm information. “All information indicated with an asterisk is required. Only ‘Volunteer Organizations’ can choose ‘None Required’ for the ‘Tax ID’ selection.” The EIN, legal name, address and phone. The ERO Locator question (“Do you want your firm/organization contact information posted on the IRS.gov public website?”) “defaults to ‘Yes’. If you do not want this posted, select ‘No’”; a withholding agent filing its own return has no reason to be listed.
2. Provider option. Large Taxpayer with Form 1042 (route 1), or ERO, Not for Profit, Large Taxpayer, Form 1042 (route 2). For a foreign EFIN the U.S. provider adds the foreign location.
3. Authorized users. “A Responsible Official is an individual with responsibility for and authority over the IRS e-file operation at designated locations. The Responsible Official is the first point of contact with the IRS and has default authorities to view and update the application and add, delete, and change Responsible Officials.” Principals (“the individuals within your firm held legally responsible by the IRS for the activities of the firm”) are required on the foreign EFIN application and not on a Not for Profit one.
4. Primary contact. “A person who will be available daily to answer IRS questions regarding this application and any processing issues throughout the year.”
5. Submission. “Enter your five-digit Personal Identification Number (PIN) from the initial registration, check the Terms of Agreement (TOA) box, and select ‘SUBMIT’. Only a Principal or designated Responsible Official can submit the application.” The PIN can be reset from the Modify PIN tab.

After submission the IRS reviews the application; the EFIN appears on the application summary when it is accepted, and MeF rule R0000-905-01 rejects any return whose EFIN is not yet “in accepted status” (see the reject rules page). Apply well before March; the IRS does not publish a processing time for Large Taxpayer applications, and a paper Form 1042 filed because the EFIN was late is a failure to e-file unless a waiver was granted.

The alternative: a provider files for you

None of this is needed if an Authorized IRS e-file Provider originates the return. A U.S. accounting firm, a withholding agent service, or the tax department of a U.S. affiliate that already holds an EFIN for business returns can e-file your Form 1042 under its EFIN, signing with Form 8453 (the signed PDF attached to the return) or the practitioner PIN method. The IRS lists approved MeF business software providers by form; Form 1042 is a short list. For a foreign withholding agent with a handful of Forms 1042-S, this is usually faster than building an e-file capability, and it keeps the ITIN and foreign-status questions out of the picture. The deposits are a separate matter: tax withheld is deposited through EFTPS on the Form 1042 schedule whoever files the return, and EFTPS enrollment for a foreign entity has its own lead time.

Questions people ask