Apply with the first payroll you can, typically the next payroll run.
Employees claiming exempt status must re-file by February 15 each year.
Implement Letter 2800C by the date in the letter, typically 60 days from the letter date.
| Trigger | Due Date / Window | Notes |
|---|---|---|
| New hire W-4 received | Apply with the first payroll you can (typically the next payroll run) | If no W-4 is on file, withhold as if the employee is Single or Married Filing Separately with no other adjustments (per IRS Publication 15-T). |
| Employee submits an updated W-4 | As soon as administratively practicable; no later than the start of the next payroll period | You are not required to implement retroactively for the current period. |
| Employees claiming "Exempt" status | Must re-file by February 15 each year | If no new exempt W-4 is received by February 15, begin withholding as Single/MFS with no adjustments until a valid form is received. |
| IRS lock-in letter (Letter 2800C) received | Implement by the date in the letter (typically 60 days from the letter date) | Overrides the employee's W-4. Do not decrease withholding below the locked rate for any reason unless the IRS issues a modification letter (2808C). |
- Current IRS Form W-4 (2026 version): Always use the version currently posted on IRS.gov. The 2026 form was updated due to tax law changes and has different values in Step 3 than prior versions. See the green section below for a direct download link.
- Employee information to verify: Legal name, SSN, filing status, any entries in Steps 2 to 4, signature, and date. Return incomplete forms before entering them in payroll.
- Payroll system access: To enter or update the withholding settings and confirm the correct tax year's tables are loaded.
- State withholding form (if applicable): Many states require a separate state withholding certificate in addition to the federal W-4. Check with your state's department of revenue; some states accept the federal form, others have their own. Collect the state form at hire wherever required.
- Retention: Keep each W-4 for at least 4 years after the later of the date the tax was due or the date it was paid.
- Format: Paper or electronic storage is acceptable. Electronic systems must maintain secure access and a reliable audit trail.
- IRS request: The IRS may ask to inspect W-4s for specific employees, typically as part of a withholding compliance review or lock-in letter process. Have a retrieval process ready.
- Privacy: Treat W-4s as confidential payroll and tax records. Limit access to payroll and HR staff who need it.
- Signed W-4sCurrent signed W-4 for every active employee, plus prior versions if updated mid-year (the IRS may want to see the history).
- Payroll change logWhen each new W-4 was received and when the new settings were applied in payroll.
- IRS correspondenceAny lock-in letters or modification letters, and documentation of your implementation timeline.
- Exempt recordsRecord of any employee who claimed exempt status, including the date of each annual re-filing.
Common traps
FAQs
Should we reject an incomplete W-4?
Yes. If the form is missing a signature, date, or filing status, return it to the employee for completion before entering it in payroll. Do not attempt to fill in missing fields yourself. Until a valid form is received, withhold as Single/MFS with no adjustments.
What does it mean when an employee claims "Exempt"?
Exempt means the employee is requesting zero federal income tax withholding. To qualify, they must have had no federal income tax liability in the prior year and expect none in the current year. They write "Exempt" in Step 4(c). This status expires annually; the employee must re-file a new exempt W-4 by February 15 each year. If they miss that deadline, begin withholding as Single/MFS with no adjustments until a new valid W-4 is received. You are not required to verify whether the employee actually qualifies; that is between the employee and the IRS.
What if an employee doesn't submit a W-4?
Withhold federal income tax as if the employee is Single or Married Filing Separately with no other adjustments (per IRS Publication 15-T). Apply this default from the first paycheck and continue until a valid W-4 is received.
Do we need state withholding forms too?
It depends on the state. Many states have their own withholding certificate (e.g., California's DE-4, New York's IT-2104, Oregon's OR-W-4). Others accept the federal W-4. Check with each state's department of revenue where you have employees.
- IRS: About Form W-4, Employee's Withholding Certificate (main page)
- Form W-4 (2026, PDF): direct download from IRS.gov
- IRS Tax Withholding Estimator (share with employees to help them complete Steps 2 to 4)
- IRS: Understanding Letter 2800C (lock-in letter guidance)
- IRS Publication 15-T: Federal Income Tax Withholding Methods (payroll withholding tables and default rules)
- Multiple jobs or working spouse: Employees in these situations should use the IRS Withholding Estimator or the Multiple Jobs Worksheet (included with the W-4 instructions) to calculate the right amounts for Steps 2 to 4. As the employer, you enter whatever they put on the form; you don't need to verify the math.
- States with their own withholding form: Collect both the federal W-4 and the state form at hire wherever required. Keep them filed together per employee. States that have their own form include (among others) California, New York, Oregon, and several others; check each state's revenue agency website for the current form.
- Remote workforce: Withholding obligations follow the employee's work location, not your office address. An employee working from home in another state may trigger that state's income tax withholding requirements and local tax obligations. Confirm requirements for each state where you have remote workers.
- Nonresident aliens: Special withholding rules apply under IRS Publication 15 and Publication 515. Nonresident alien employees generally cannot claim exempt and have specific W-4 completion instructions; consult IRS guidance or a payroll advisor for these situations.
Download the current 2026 form directly from IRS.gov, and share the Withholding Estimator link with employees who have complex situations; it walks them through Steps 2 to 4 without requiring them to understand the underlying math.
- Form W-4 (2026, PDF): direct download from IRS.gov
- IRS About Form W-4: always links to the current version and instructions
- IRS Tax Withholding Estimator: recommend to any employee who has multiple jobs, a working spouse, dependents, or other income
- IRS Publication 15-T: Federal Income Tax Withholding Methods (the employer reference for default rules and withholding tables)