Your trusted partner for accurate, on-time 6039 reporting.

Eliminate stock plan reporting risk with 6039 compliance support.

The Challenge

6039 reporting leaves little margin for error when deadlines and data collide.

  • Equity data is fragmented across platforms, increasing reporting errors
  • Ownership spans HR, Legal, Finance, and Payroll, creating gaps
  • Year-end deadlines limit time to resolve data and withholding issues
  • Errors surface late, when fixes are costly and highly visible

The result is higher compliance risk, delayed filings, and added stress.

The Solution

We provide experienced oversight that ensures accurate, on-time 6039 reporting with minimal internal burden.

  • Expert management of Forms 3921 and 3922 from start to finish
  • Clear, repeatable processes aligned with IRS requirements
  • Proactive coordination across equity platforms, brokers, and payroll
  • Secure handling of sensitive equity and tax data

The result is compliant 6039 reporting delivered with confidence.

Core Capabilities

Our 6039 services are designed to simplify compliance while reducing risk and administrative burden. This includes:

  • Preparation and e-filing of Forms 3921 and 3922 with the IRS
  • Guidance and support for additional EIN filing requirements
  • Direct access to 6039 subject-matter experts
  • Employee statement printing, mailing, and distribution
  • Custom communication inserts included with employee statements
  • Digital employee statement options
  • Comprehensive data review to ensure IRS-compliant reporting
  • Secure data handling supported by SOC 2-certified processes
  • Transparent project management with clear timelines and communication

Your Dedicated Support Team

Our experienced professionals are dedicated to providing timely, reliable, and secure solutions, so you can confidently meet your reporting obligations with ease.

  • Dedicated Project Manager: Enjoy white-glove project guidance from start to finish.
  • Data Security: Ensure secure data upload and download via our Atlassian-based system.
  • Traceable, Secure Mailing: We handle participant forms with precision and care.
  • Informative Participant Letters: Included with most services for added clarity.
  • Electronic Filing: We handle IRS submissions, eliminating the need for complex file formatting or obtaining a TCC.
  • Late Filing Assistance: Need extra time? Our experts can guide you through the extension process.

Platform Flexibility

We integrate seamlessly with all major equity management platforms. These include:

  • Morgan Stanley ShareWorks
  • Fidelity
  • E*TRADE / Morgan Stanley at Work
  • Carta
  • Charles Schwab
  • BAML
  • Certent
  • Computershare
  • UBS
  • Global Shares

How We Work

1. Discovery & Data Intake

We help gather and organize all required data for accurate reporting.

2. Data Validation & Audit

Automated checks flag missing tax IDs, mismatched dates, and inconsistent values.

We review every record for accuracy.

3. Statement Generation

Accurate Form 3921 and 3922 statements are generated and verified for each participant.

4. Employee Distribution

Printed and mailed statements ensure timely employee delivery.

5. IRS Submission & Confirmation

Files are securely transmitted through the IRS FIRE system with confirmations logged and archived.

6. Post-Filing Support

SOS manages corrections and re-filings—no additional lift for your team.

FAQs

What are 6039 Services?

6039 Services ensure your company meets IRS Section 6039 requirements for stock plan reporting. This includes preparing, printing, mailing and filing Forms 3921 and 3922, validating your data, and submitting everything electronically to the IRS. 

Who needs 6039 reporting?

Any company that offers either: 

  • Incentive Stock Options (ISO) 
  • Employee Stock Purchase Plans (ESPP) qualified under Section 423 

must file Form 3921 (ISO exercises) and Form 3922 (ESPP transfers/purchases). 

What are the IRS 6039 statement and filing deadlines?

Employee statements must be mailed by: January 31 
IRS electronic filings must be completed by: March 31 

If the date falls on a weekend/holiday, the deadline shifts to the next business day. 

Are companies required to file electronically?

Yes. If you file 10 or more total information returns, the IRS requires e-filing starting in 2024. This threshold includes all returns your company files (W-2, 1099, 3921, 3922, etc.). 

What happens if we do not meet the deadlines?

IRS penalties increase based on how late the filing is: 

  • $60 per form if filed within 30 days 
  • $120 per form if filed by Aug 1 
  • $310 per form after Aug 1 
  • Intentional disregard penalties start at $630 per form with no maximum 

Late or incorrect employee statements can trigger additional penalties. 

Can we request an extension?

Yes, but the rules have changed for 2024 and forward.

IRS filing extension (to file with the IRS):
Submit Form 8809 by the original due date to request an automatic 30-day extension.

Extension to furnish employee statements (BIG CHANGE):
The old rule required a written letter mailed to the IRS.
This is no longer allowed.

Starting with 2024 filings, companies must now request an extension electronically using Form 8809 just like the IRS filing extension.

Summary of the new rule:

  • Employee statement extension requests must be submitted via Form 8809

  • Electronic filing only

  • No more mailed letters

  • Not automatically granted (IRS approval required)

Source:
IRS Publication 1220, Section 8 (Extensions)
https://www.irs.gov/pub/irs-pdf/p1220.pdf

Can SOS handle both ISO and ESPP reporting?

Yes. We manage both plan types and validate all required fields for IRS compliance. 

Do I need to use a specific equity platform?

No. We work with: 
ShareWorks, Equity Edge Online, Fidelity, E*TRADE/Morgan Stanley, Schwab, Carta, and all other major systems. 

What if I'm missing data or have inconsistencies?

We identify and help resolve issues such as: 

  • Missing SSNs 
  • Incorrect fair market values 
  • Mismatched grant/exercise dates 
  • Incorrect EINs 
  • Missing or partial share counts 
What if an employee left the company?

You must still send their Form 3921 or 3922. SOS can help confirm addresses. 

Do private companies have to file too?

Yes. Public and private companies have the same requirements. 

Why Companies Choose SOS

Expertise

Over 25 years of CEP-level mastery ensure that even your most complex equity compliance and reporting requirements are met with precision.

Partnership

We bridge experience and bandwidth gaps by integrating with your team. This provides the steady hand required to navigate your equity operations at every stage of growth.

Responsiveness

We provide direct, immediate access to our experts, ensuring you have the support you need when you need it.

Experience the confidence of a fully-supported equity team—bringing you total peace of mind.

Talk to an Expert