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Per the New York Tax preparer e-file mandate web page:

If you can't electronically file the return because it's not supported by your approved e-file software or it can't be filed on our Web site, then you aren't required to e-file it.

Additional information for preparers is available on the New York State website:

Penalties for both Preparers and Individuals are outlined on the New York website E-file - mandate for business taxpayers:

Penalties for failing to electronically file

If you or your preparer are required to file a tax document electronically and instead file on paper, you're subject to the following penalties:

  • $50 penalty for each tax document not electronically filed;
  • $50 penalty for failure to pay electronically; and
  • a penalty specific to your tax type for failure to file.

In addition, any overpayment claimed on a return that was required to be electronically filed won't be eligible to receive interest until the document is filed electronically.

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