Research Participant Payment & Tax Reporting Update: What You Need to Know

Effective January 1, 2026, the IRS reporting threshold for research participant payments has increased from $600 to $2,000 per calendar year. This means:

• Form 1099 Requirement: Sponsors will issue a Form 1099 (Miscellaneous Income) to non-employees who receive $2,000 or more in research participant payments during a calendar year.
• Taxable Income: All research payments remain taxable, regardless of amount. The threshold only determines when a Form 1099 is issued.
• Consent Form Updates:
  • New consent forms must include the updated templated language explaining the $2,000 threshold.
  • WCG expects previously approved ICFs to be updated by clients and submitted for review.  
  • WCG will be adding a process to check and update in any ICFs we review going forward, but we will not update ICFs that are already approved and are not being modified by sites/sponsors
  • We will notify our clients by a web post that they should update their ICFs with this new information.  
  • For ongoing studies, teams should either provide participants with an IRB-approved information sheet or verbally notify them, and update consent forms at the next IRB-submitted modification.
  • If a client wants to submit a letter in lieu of an ICF update, they can submit that for review.  WCG will consider approving a letter through our generic process and they can discuss this process with WCG Client Care.

Key Takeaways:

• Does this change affect payments under $2,000? No. All payments are taxable.
• What if my consent form still lists $600? No need to halt enrollment. Submit an updated ICF or information sheet/letter for IRB review. Once approved, notify participants, document in the research record, and/or update the ICF at the next review.
• Is written reconsent required? No, as long as participants have been documented to have received the information via the information sheet or verbal notice.