Effective January 1, 2026, the U.S. IRS reporting threshold for research participant compensation has increased from $600 to $2,000 per calendar year. While the institutional reporting threshold to the IRS has increased, the fact that research participant compensation is taxable income remains unchanged. Reimbursement for documented participant expenses related to participation is not taxable.
New Study Submissions:
Study teams should use the following updated template language in their consent materials when participants will receive financial compensation for participation:
Will I be paid for participation?
You will be paid [describe payment, including the amount, method, timing, and any conditions for receiving payment. When research involves multiple visits or interactions, payment should be prorated and not be contingent upon completion of the entire study.
Payments you receive for participating in research are generally considered taxable income under U.S. tax law. If the total amount you receive from [Institution Name] for research participation in a calendar year is $2,000 or more, [Institution Name] is required to report these payments to the Internal Revenue Service (IRS) and may issue you an IRS Form 1099. To meet this requirement, you may be asked to provide information such as your name, address, and Social Security Number, as required for IRS reporting.
If the total amount you receive is less than $2,000, a tax form may not be issued. However, you are still responsible for reporting all taxable income on your tax return.
[ ] Check this box if you wish to opt-out of receiving payment for participation.
Existing Studies with Active Participants:
For already approved studies with participant payments, study teams should inform active participants of the change in IRS reporting and submit updated consent language for approval with the next amendment, continuing review, or status report submitted to the IRB (whichever comes first).
Active participants, and any newly enrolled participants (enrolled prior to approval of revised consent materials), can be notified of the change using one of the following methods:
- Verbal notification at the time of the next interaction with the participant, using the new template language as a script. The date and time of participant notification, as well as a summary of the information provided, should be recorded in the study records.
- Provision of the [Institution Name] IRB-approved IRS Reporting Update Information Sheet. For new participants, the Information Sheet can be presented as a Consent Addendum. For already enrolled active participants, the Information Sheet can be provided at the time of the next interaction with the participant. The date and time of participant notification should be recorded in the study records, along with a copy of the Information Sheet.
Please note that the IRS Reporting Update Information Sheet is IRB-approved and cannot be modified other than insertion of the PI name, protocol title, and contact information where indicated.
Download Sample IRB Instructions
Download Sample Information Sheet