2023 irs efile mandate threshold for 2022 informational returns

https://www.irs.gov/e-file-providers/frequently-asked-questions-e-file-requirements-for-specified-tax-return-preparers-sometimes-referred-to-as-the-e-file-mandate

Believe if paid preparer does 10 or more e-filing is required.

Were you considering not e-filing if you were below the threshold?

The IRS doesn't even have the procedures or the portal in place:

https://www.irs.gov/instructions/i1099gi#en_US_2022_publink1000286931

If it is not functioning, they can't enforce it.

https://news.bloombergtax.com/payroll/bill-drops-250-form-w-2-electronic-filing-threshold-to-10

"A bill that greatly reduces the maximum number of Forms W-2 employers can file on paper was signed July 1 by President Donald Trump.

The Taxpayer First Act reduces the threshold that triggers the electronic filing requirement for the combined filing of most information returns to the IRS, including Forms W-2, Wage and Tax Statement, and the Form 1099 series. The threshold, now 250 forms, would fall to 100 for 2021 forms filed in 2022 and to 10 forms for 2022 forms filed in 2023 and subsequent years.

The bill (H.R. 3151) was bipartisan legislation that restructures the Internal Revenue Service. Additionally, the law establishes an independent Office of Appeals to help resolve taxpayer disputes and prevents the IRS from referring low-income taxpayer debtors to private collection companies."

According to this webpage:

The Taxpayer First Act of 2019, enacted July 1, 2019, authorized Treasury and the IRS to reduce the 250-return requirement for 2022 tax-year returns. We have proposed regulations to reduce the current 250-return threshold to  10 in 2023. see the Federal Register To review the proposed regulation or for details on the public hearing and comment period. If those regulations are issued and if they are effective for 2022 tax-year returns required to be filed in 2023, we will post an article at IRS.gov/form1099 explaining the change.  Until final regulations are issued, however, the number remains at 250. 

https://www.irs.gov/e-file-providers/filing-information-returns-electronically-fire