news article

Reminder regarding New York State New Hire Reporting Requirements

September 23, 2025 / By Tracy Rickett, UNY Human Resources Manager / .(JavaScript must be enabled to view this email address)

This is a reminder for all churches regarding New York State’s new hire reporting requirements.

Who must report new hires

All employers in New York State must report certain identifying information about each newly hired or rehired employee working in New York State.
A newly hired or rehired employee means an employee:

• previously not employed by the employer, or
• previously employed by the employer but separated from such prior employment for 60 or more consecutive days.

Important: Effective January 1, 2022, employers are required to report individuals under an independent contractor arrangement with contracts in excess of $2,500.
You must report new hires if you meet the definition of an employer under federal income tax withholding.

Information you must report

You must provide the following information:

• employee name (first, middle initial, last),
• employee address (street, city, state, and ZIP code),
• employee Social Security number,
• employee hire date,
• employer name,
• employer address (street, city, state, and ZIP code),
• employer identification number (assigned by the Internal Revenue Service), and
• if dependent health insurance benefits are available to the employee and if so, the date the employee qualifies for the benefits.

Due dates

You must report newly hired or rehired employees who will be employed in New York State within 20 calendar days from the hiring date. The hiring date is the first day the employee:

• performs any services for which they will be paid wages, tips, commissions, or any other type of compensation, or
• is eligible to earn commissions, for services based solely on commissions.

If you report electronically, you must submit two monthly reports (if needed) between 12 and 16 days apart.

This timeframe is also applicable for independent contractor reporting.

Reporting Methods

Employers who are required to report to New York State should use one of the methods below to submit the new hire information:

• Online via the New York New Hire Online Reporting Center

Note: Employers must report individuals under an independent contractor arrangement with contracts in excess of $2,500 using the online reporting link above, not Form IT-2104.

• Submit a copy of the employee's Form IT-2104, Employee's Withholding Allowance Certificate, in place of, or in addition to, the federal Form W-4, Employee's Withholding Certificate1:

1. Fax: 518-320-1080
2. Mail to: New York State Dept of Taxation and Finance, ATTN: New Hire Notification at P.O. Box 15119, Albany, NY 12212-5119

If you utilize a Human Resources and/or Payroll processing company, the company may submit the new hire report on your behalf. It is recommended to check with the processing company regarding new hire reporting, including independent contractor reporting.

Note: You do not have to report or file copies of Form IT-2104 or federal Form W-4 for existing employees who change deduction amounts or other information.

Penalties

If you fail to: timely report newly hired employees, the penalty is: $20 x number of employees not reported
If you fail to: file a report showing the required information, the penalty is: $20 x number of false or incomplete reports filed

Assistance

To assist employers, New York State has frequently asked questions (FAQs) available on their website. You may also contact the New York New Hire Employer Outreach Department at 518-320-1079.

Next Steps

Churches should review their procedures for reporting new hires and independent contractors whose contracts are in excess of $2,500. The $2,500 threshold can be a single agreement or additional agreements that increase the amount above $2,500.

If you have any questions on this topic, please contact Tracy Rickett, Human Resources Manager, at 315-898-2017 or TracyRickett@unyumc.org.


1Form IT-2104 contains the required information regarding employee dependent health insurance benefits and the hire date. Review Form IT-2104 and federal Form W-4 to ensure the information is complete and legible, including the employer's name, address, and identification number.