OBBBA year-end guide
W-2 Reporting, Box 12 and Box 14
New reporting fields carry qualified tips, qualified overtime, and the tipped occupation code onto the W-2. 2025 gets transition relief; 2026 forms are built for it.
The 2025 W-2 (produced in January 2026)
The 2025 Form W-2 was already finalized before OBBBA reporting rules were settled, so the IRS provided transition relief for tax year 2025: employers are not penalized for failing to separately report qualified tips, qualified overtime, or the tipped occupation code on the 2025 form.
Relief is not the same as silence. Employees will be asked to substantiate their deduction, and they will come to you for the number. Our recommended approach is to furnish the figures we can support — typically in Box 14 and, where useful, on a separate employee statement that accompanies the W-2.
That means the decisions on this site still matter for the 2025 filing season, because the amounts have to be derivable from the payroll data we already hold.
The 2026 W-2 and forward
The 2026 form adds dedicated fields for this reporting: a Box 12 code for total qualified tips, a Box 12 code for total qualified overtime compensation, and a Box 14 area for the Treasury Tipped Occupation Code.
Because those fields are structured and machine-matched, the underlying earnings-code setup has to be right from the first payroll of the year, not fixed at year end.
What has to be true in payroll
- FLSA-required overtime premium sits in its own earnings code, separate from state-only or contractual premium pay.
- Qualified tips are distinguishable from service charges and auto-gratuities.
- Every tipped employee is mapped to a TTOC.
- Regular-rate inputs (bonuses, commissions, differentials) are identified so premiums are calculated correctly.
- Any mid-year corrections are made before the final payroll of the year, so no amended W-2s are required.
Year-end timeline
Submit your answers as early as possible, and no later than your final scheduled payroll of the year. Changes after the final payroll may require corrections, and changes after W-2s are issued require a W-2c.
This site is general educational information about payroll reporting under the One Big Beautiful Bill Act (OBBBA). It is not tax, legal, or accounting advice. Guidance from the IRS and Treasury continues to evolve — confirm your specific facts with your tax advisor and your Time & Pay representative before you rely on it.