Form 8948: Paper Filing Exception Reasons and Hardship Waiver

Form 8948 is the IRS form a paid tax preparer attaches to a paper-filed income tax return to explain why the return wasn’t filed electronically. It applies to preparers who fall under the e-file mandate in IRC § 6011(e)(3), and it travels with the paper return itself rather than going to the IRS separately.¹

Who Has to Use Form 8948

The form is only for a “specified tax return preparer.” That means a preparer who reasonably expects to file 11 or more covered returns (primarily Forms 1040 and 1041) during the calendar year. Expect to file 10 or fewer? You’re below the threshold, you can file on paper, and Form 8948 isn’t your concern.¹

Two things to keep in mind on the count. It’s based on what you reasonably expect at the start of the year, not your final total. And if you work at a firm, the count aggregates across the firm’s members, not just your own clients.²

Returns the IRS can’t accept electronically don’t count toward the threshold, and neither do returns your clients plan to mail in themselves.³

When the Form Is Required and When It Isn’t

If you’re a specified preparer and a covered return goes out on paper, Form 8948 is your explanation. One carve-out: if the IRS doesn’t accept that return type electronically at all, and the attached forms or schedules can’t be transmitted separately with Form 8453 or Form 8453-F, you don’t need Form 8948. The IRS already knows there’s no electronic path for that return.²

The Six Reasons You Can Check

After the identifying information for the taxpayer and the preparer (including your PTIN), the form asks you to check one box, and only one, that explains the paper filing:²

Box 1 is for a taxpayer who chose paper. This is the most common reason and is a recognized exception.
Box 2 is for an approved hardship waiver. You previously submitted Form 8944 and received an IRS approval letter.
Box 3 is for a preparer who is a member of a recognized religious group conscientiously opposed to electronic filing.
Box 4 covers e-file rejections you couldn’t resolve after attempting to transmit the return.
Box 5 is for software limitations, where your e-file software doesn’t support a form or schedule attached to the return.
Box 6 is for other circumstances, including foreign preparers without a Social Security number who live and work abroad, preparers ineligible to participate in IRS e-file, and other specific reasons you describe in writing on the form.

Pick the box that actually matches the situation. The form is a statement to the IRS about your compliance with the e-file mandate.

How to File It

Attach the completed Form 8948 to the paper return before giving it to the taxpayer to sign. It then goes to the IRS with the mailed return. There is no separate submission and no electronic version of the form.²

An approved hardship waiver doesn’t excuse you from the form. You still attach Form 8948 to each paper return and check Box 2. The waiver gives you a valid reason to check; the form is still what documents it.²

If You Need a Hardship Waiver First

Box 2 only works if you’ve already gone through Form 8944, the hardship waiver request. The IRS accepts those requests between October 1 and February 15 for the upcoming filing season. For the 2025 tax year, that window runs October 1, 2025 through February 15, 2026. Late requests are considered only in limited circumstances and must include a statement explaining the delay.⁴

Recognized hardship categories include bankruptcy, economic hardship, being located in a presidential disaster area, and other circumstances such as lack of internet access. Economic hardship claims require additional financial information on the form. The IRS will not grant a waiver on the grounds that you lack an Electronic Filing Identification Number, which it treats as something you can resolve.⁴

What Happens If You Skip It

Mailing a paper return without Form 8948 when you’re a specified preparer leaves no record that you had a valid reason to file on paper. The IRS can assess penalties against specified preparers who don’t comply with the e-file requirement under IRC § 6011(e)(3), and a properly completed Form 8948 is the evidence that one of the recognized exceptions applied.¹

Separately, the statute itself provides a narrow geographic exception. If your practice is located in an area without internet access beyond dial-up or satellite, the IRS may waive the e-file requirement entirely on application, without the Form 8944 process.¹

1
Office of the Law Revision Counsel. 26 USC 6011 – General Requirement of Return, Statement, or List
2
Internal Revenue Service. Form 8948 – Preparer Explanation for Not Filing Electronically
3
Internal Revenue Service. Frequently Asked Questions – E-File Requirements for Specified Tax Return Preparers
4
Internal Revenue Service. Form 8944 – Preparer e-File Hardship Waiver Request