CA E-File Waiver: Who Qualifies, How to Apply, and Penalties

A California e-file waiver is handled through one of four separate processes, and which one you use depends entirely on what you file. Business entities request a waiver through the Franchise Tax Board’s online system, and for the 2026 calendar year those requests are approved on submission. Individual taxpayers whose preparers are required to e-file simply sign a one-page opt-out form the preparer keeps on file. Filers of 250 or more information returns submit a paper Form 6274 by mail or fax. The mandatory e-pay rule has its own waiver on Form 4107.

Figuring Out Which Waiver You Need

California runs three distinct e-filing mandates and one e-payment mandate, each with its own exit.

You’re subject to the business entity mandate if your corporation, partnership, or LLC prepared its return using any commercial tax software. The trigger is software use, not revenue or return count.1State of California Franchise Tax Board. e-file for Business

You’re subject to the preparer mandate if you are a tax preparer who filed more than 100 California individual returns in a year and used software for at least one of them. All of your individual California returns then have to be e-filed.2Franchise Tax Board. 2025 Handbook for Authorized e-file Providers If you are the individual client of such a preparer, the opt-out below is your path.

You’re subject to the information return mandate if you submit 250 or more Forms 1099, 1098, W-2G, or similar information returns to the FTB in a year.3State of California Franchise Tax Board. Information Returns

Separately, the mandatory e-pay rule kicks in for individuals who make a single estimated tax or extension payment over $20,000, or who file a return with total tax liability over $80,000. Every payment after that must be electronic.4State of California Franchise Tax Board. Mandatory e-Pay for Individuals

Business Entity E-File Waiver

Business entities request the waiver through the FTB’s online form at webapp.ftb.ca.gov/ewaiver. There is no downloadable paper version. The form asks for the entity’s name, identification number, tax form type, accounting period, and a written explanation of why e-filing is not feasible.

The FTB recognizes three grounds: technology constraints (your software cannot transmit the return electronically), undue financial burden (the cost of required software or hardware is disproportionate to the entity’s resources), and other circumstances constituting reasonable cause.5Franchise Tax Board. Business Entity e-file Waiver Request A preference for paper filing does not qualify.

You must request the waiver annually, for each tax year and each entity.5Franchise Tax Board. Business Entity e-file Waiver Request

Timing

For the 2026 calendar year, the FTB approves business entity waiver requests upon submission, so you can file your paper return right after completing the online form.5Franchise Tax Board. Business Entity e-file Waiver Request Submit the waiver before filing your paper return, or no more than 15 days after.6California Franchise Tax Board. Business Entity e-file Waiver Request Miss that 15-day window and your paper return sits with the FTB without protection, exposing you to penalties. Waiver requests for future tax years may be subject to review before approval, so the auto-approval window is a 2026 feature, not a permanent policy.

Writing the Hardship Explanation

Keep it specific. For a technology constraint, name the software you use and identify exactly what blocks electronic transmission, such as an unsupported form or a documented compatibility error. For financial hardship, state the cost of the required software or equipment and compare it to the entity’s annual revenue or budget. Vague statements such as “e-filing is inconvenient” do not meet the standard. Documentation matters more in years when automatic approval no longer applies.

Individual Taxpayer Opt-Out

If your preparer is required to e-file and you would rather file on paper, you have a statutory right to say no. Revenue and Taxation Code Section 19170 treats a taxpayer’s election not to e-file as reasonable cause for the preparer to submit a paper return.2Franchise Tax Board. 2025 Handbook for Authorized e-file Providers

You and your preparer complete FTB Form 8454, the e-file Opt-Out Record for Individuals.7State of California Franchise Tax Board. e-file for Individuals Do not mail it to the FTB. Your preparer keeps it as proof you elected paper filing. No FTB approval is needed and no hardship justification is required. This is the simplest of the four processes because it rests on taxpayer choice rather than demonstrated inability.

Information Return Waiver

If you must file 250 or more information returns electronically but cannot, submit FTB Form 6274, the Waiver Request From Filing Information Returns Electronically.3State of California Franchise Tax Board. Information Returns It is a downloadable PDF on the FTB website. This waiver is not handled through the online system.

The form asks for the types of returns involved, the volume you anticipate filing, and a detailed explanation of why electronic filing is not possible. Attach supporting documentation: a letter from your software vendor confirming the system cannot transmit the returns, or financial records showing that compliant software would be prohibitive.

Mail the completed and signed form to:8Franchise Tax Board. FTB Form 6274 – Waiver Request From Filing Information Returns Electronically

State of California
Data Resources and Services MS A181
Franchise Tax Board
PO Box 1468
Sacramento, CA 95812-1468

You can also fax it to 916-855-5555. The FTB issues a written determination. Submit the request well ahead of your filing deadline; approval here is not automatic.

E-Pay Waiver

The mandatory electronic payment requirement is a separate rule with its own waiver. If you’ve crossed the $20,000 or $80,000 threshold and cannot pay electronically, download FTB Form 4107, complete it, and send it with documentation supporting your request.4State of California Franchise Tax Board. Mandatory e-Pay for Individuals

Fax to 916-843-0468 or mail to:

State of California
Franchise Tax Board
PO Box 942840
Sacramento, CA 94240-0040

Pursue this waiver before mailing a check. The penalty for making a required payment by non-electronic means is 1% of the amount paid. On an $80,000 payment, that is $800 you avoid by either filing the waiver or switching to electronic payment. Also useful to know: the first payment that puts you over the threshold does not itself have to be electronic.9Franchise Tax Board. 2025 Instructions for Form 540-ES Estimated Tax for Individuals

What It Costs to Skip the Waiver

Paper-filing without a waiver when you were required to e-file carries escalating penalties for business entities: $100 for the first failure, $500 for each subsequent failure.10Franchise Tax Board. FTB 1024 – Penalty Reference Chart These apply solely to using the wrong filing method and stack on top of any late-filing or late-payment penalties.

The FTB will consider reasonable cause when assessing these penalties. If a penalty was assessed and genuine circumstances prevented compliance, you can request abatement. The strongest cases involve documented events outside your control, such as a system outage during the filing window, a natural disaster, or a sudden change in your software vendor’s capabilities. Forgetting the mandate or preferring paper will not clear a penalty after the fact, which is why the waiver, filed on time, is almost always the better move.