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@sjrcpa wrote:

Yes. There is no requirement to efile 1040X so you don't need 8948.

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My understanding is that 1040X is now under e-file mandate.  I would, therefore, include a F.8948 with a 1040X filed on paper.

It was originally covered under administrative exemptions per Notice 2011-26 only because e-filing for amended return was not available at that time.

Notice 2020-70 was subsequently issued to remove 1040-NR from the list of administrative exemptions provided for under the previous notice and stipulates that "future updates to the list of returns in Notice 2011-26 that are administratively exempt from the electronic filing requirement due to IRS e-file limitations will be provided for in IRS Publication 4164."

Interestingly, e-filing of 1040-NR (other than dual status returns) was made possible the same year as 1040X but Notice 2020-70 covers only 1040-NR.

Notwithstanding the omission of 1040X in Notice 2020-70, Publication 4164 has since been updated to reflect the change.  If we refer to Section 1.6, we will see that 1040X is no longer exempt unless it is a dual status return, the original was not e-filed (which makes the amended return ineligible for e-filing), or that it was for tax years prior to 2019, the first tax year e-filing was made possible (which should really be 2021 now based on the 1 + 2 formula).