Do I have to send my fractional CMO a 1099 for 2026?
The new $2,000 threshold for 2026 payments, the January 31 deadline, and the cases where no 1099-NEC is needed at all.
Only if your business paid the fractional CMO $2,000 or more during 2026 and the CMO is not a corporation. For payments made in 2026 the IRS reporting threshold for nonemployee compensation on Form 1099-NEC rose to $2,000, up from the $600 that applied to payments before 2026. The form goes to the CMO and to the IRS by January 31.
Most fractional CMO retainers clear $2,000 in the first month, so the threshold rarely changes the answer for an engagement that ran most of the year. It matters for a short advisory project, a one-off workshop or a few hours of paid review. Under the old rule a $1,500 strategy session triggered a form. For 2026 payments it does not.
The IRS page on who must file says the threshold for payments after 2026 will be in Publication 1099, and the form instructions say it may be adjusted for inflation beginning in calendar year 2027. Check the amount again next year before you assume $2,000 still applies.
Three situations take a payment off the 1099-NEC entirely.
The first is a corporation. The instructions say payments to a corporation, including an LLC that is treated as a C or S corporation, are generally not reported. Many fractional CMOs bill through their own company, so ask how that company is taxed. The exception is written for an LLC treated as a C or S corporation, so an LLC that has not made that election does not get it automatically. Your accountant can confirm which side a given vendor falls on.
The second is how you paid. Payments made by card or through a payment network belong to Form 1099-K, a separate form, so they are not reported again on a 1099-NEC. If you paid part of the year by ACH and part by card, only the ACH portion counts toward the $2,000.
The third is an employee. A fractional CMO on your payroll gets a W-2 and no 1099. Whether someone should be on payroll is a separate question about control and independence. The IRS has its own guidance on that, and this note does not answer it for you.
One exception runs the other way. If you withheld federal income tax under backup withholding, for example because the CMO never gave you a taxpayer identification number, you must file a 1099-NEC for that person whatever the amount. Getting a Form W-9 before the first invoice is paid avoids that problem.
Two practical points for year end. If you file ten or more information returns of any kind, the IRS requires you to file them electronically. And the January 31 date applies both to furnishing the copy to the CMO and to filing with the IRS, so the W-9 you collect now is what makes that date easy.
None of this is tax advice for your situation. Your accountant has the final word on how your payments are classified.
If you are still deciding whether a fractional CMO is worth the retainer in the first place, the four-minute diagnostic on this site scores whether your company needs one or should buy something else.