There is a reason this question is hard to search. The work is new — the 2026 Form W-2 is the first one to carry Box 12 codes TT and TP, and nothing was required on a 2025 W-2 — so there is no established category of provider, no comparison grid, and no going rate. What exists instead is four different kinds of organisation, each of which can do part of it.
Below is what each of them actually publishes, rather than what one would infer. Where a claim is sourced it is sourced; where the honest answer is “ask them,” that is what it says.
1. Your payroll provider
They are the obvious first call, and structurally they are in the best position: they already hold every pay period of the register, which is the raw material the derivation needs. If they will backfill the split for the periods already run, that is the cheapest and cleanest route available and nothing on this site improves on it.
The question is whether they will. Writing in November 2025, Ryan — a global tax services firm — observed that many third-party payroll providers would not have a solution in place for 2025. That was a statement about 2025, when nothing was required, and it should not be read as a claim about where any provider stands today. But it points at the right question to put to yours, which is not “will you support code TT” — nearly everyone will, going forward. It is:
Will you go back and split the periods that have already run this year, or does support start from the next cycle? Forward-only support is the common shape, and it is the shape that leaves you with the problem, because the periods already run are the ones the 2026 W-2 has to report.
2. A national tax consultancy
The large tax firms are engaged on this. Ryan publishes a page on qualified overtime wage reporting, dated 19 November 2025, and the scope it offers is stated plainly: to strategize qualified overtime calculations and reporting, to help determine the qualified overtime wages to report to employees, to draft a communication strategy and workplan for when those figures will be calculated and provided, and to prepare an FAQ document for impacted employees or for payroll and HR staff.
Read that list for what it is. It is advisory — a firm that will help you decide how to approach the problem, agree a method, and communicate it. That is genuinely valuable on a question this new, and for an employer with a complicated regular rate, several jurisdictions or a union agreement in play, it is very likely the right call. It is not a criticism of the shape to say it is a different shape.
Two practical notes. The page carries no price, no minimum and no turnaround, so the cost is whatever a scoping conversation produces. And it addresses qualified overtime only — code TP and the tips side are not covered there. If you have tipped employees, that is a second conversation.
3. Your accountant
Almost every employer asks their CPA first, and for the parts that are judgement — how an unusual bonus structure folds into the regular rate, whether a given role sits on the published tipped-occupation list — that is exactly right.
The friction is that the bulk of this is not judgement. It is arithmetic repeated across employees × pay periods, and it needs a register export the practice usually does not hold. The realistic outcome is that your accountant tells you what basis to use and someone else runs it across the data, which is the same division of labour as the option above, at a different scale. Worth asking directly whether they intend to run the periods themselves or review the output of someone who does.
The published guidance from the CPA side is worth reading closely, because it is precise about the requirement and silent about the backfill. Warren Averett, a CPA and advisory firm, published a payroll-reporting piece on 4 February 2026 stating that your payroll system must be updated to properly track qualified overtime (Form W-2 code TT), qualified tips (Form W-2 code TP) and nonqualified overtime and tips as separate categories, and that qualified overtime includes only overtime paid under FLSA overtime rules — overtime paid outside FLSA guidelines does not qualify and must be tracked separately. That is a correct and useful statement of the requirement, and it matches what the code TT guide works through.
What it then tells employers to do is contact their payroll provider and confirm three things: that the new 2026 tracking categories are available, that codes TT and TP will be correctly supported, and that reporting will meet requirements. Every one of those three is a question about capability going forward. None of them asks what happens to the pay periods that have already run in 2026 under the old category structure — and on a 2026 Form W-2, those periods are not optional history. They are part of the figure in the box. That is not an oversight in the guidance; it is a readiness checklist, and it does the job a readiness checklist does. It just means the fourth question is yours to ask.
4. A fixed-fee reconstruction
This is what Truing is, and stating the boundary is more useful than a pitch. It is not advisory. It does not decide your method for you or negotiate a position — it takes a payroll register, applies a stated basis, and returns the derivation.
What arrives is a per-employee workbook showing the working behind every figure, a W-2 import file, a method memo recording the basis used, an exceptions report naming every employee whose figure could not be derived from the data supplied, and a reconciliation back to the register totals. It covers code TT and code TP. The price is $350 minimum, then $8 per employee, which the cost guide sets against the published penalty amounts.
The exceptions report is the part worth understanding before buying. A reconstruction cannot invent data the register never held, and pretending otherwise is the failure mode of this entire category. Naming the gaps is the deliverable, not an apology for one.
The question that actually decides it
All four options price against the same unknown: whether your payroll register holds what the derivation needs. Code TT is the overtime premium — the half-time increment — not total overtime pay, and deriving it per period requires the overtime hours separated from straight time and the regular rate as actually computed for that period, including any non-discretionary bonus, shift differential or commission that folded into it. That is worked through in the guide on why code TT is the premium. Code TP works differently again: it carries cash tips as reported to you, which is not the same set as the employee’s qualified tips, and that is in the code TP guide.
Until someone has looked at an export, every quote you get — from any of the four — is sized off headcount, and headcount is the wrong unit. The unit is employees × pay periods, so a forty-person shop paying weekly is roughly twice the job of the same shop paying semi-monthly, at the same headcount and the same quoted price.
The free readiness check reads a register export and counts how many employees can be classified from the data already on hand. It is worth running before any of these conversations, whichever way you go — a provider that says “forward only” and a firm quoting a scope are both easier to answer when you know what your own data supports. The register is read in the request and not stored.
On timing
One thing is common to every route. The 2026 Forms W-2 are due 1 February 2027, and the information-return penalty for a wrong Box 12 figure is published per return, indexed annually, and keyed to the year the return is due. For returns due in 2026 the top tier is $340 per return, with $680 for intentional disregard. The figures that will actually govern the 2026 Forms W-2 are the returns-due-in-2027 amounts, and the IRS had not published that row as of the date at the top of this page. Anyone quoting you a precise 2027 penalty is quoting a number that does not exist yet.
The practical consequence is not urgency for its own sake. It is that the register export every one of these four options depends on is hardest to get out of a payroll platform in January, and easiest in the middle of the year — which is the one part of the decision that gets worse by waiting, whoever ends up doing the work.
The first applicable tax year, the 1 February 2027 due date and the penalty amounts were verified against IRS primary sources on 31 July 2026 and re-checked on 1 August 2026. Ryan’s published scope was read from its own page, dated 19 November 2025, and Warren Averett’s from its own page, dated 4 February 2026; both are quoted as published, are described as differences in shape rather than in quality, and are neither endorsements nor comparisons. Amounts for returns due in 2027 were still not published as of 1 August 2026 and are not claimed here. Nothing on this page is tax advice.