We would like to allow employees to update their W4 in ESS but have been reluctant because we have been unsure that we can provide the appropriate records. The IRS Website states that you must be able to supply a hardcopy of an electronic Form W-4. For those of clients that have opened up the W4 for update in ESS, how are you producing a hardcopy for employer records?
Recordkeeping Requirements
After the employee completes and signs the Form W-4, you must keep it in your records for at least 4 years (See Publication 15, (Circular E), Employer's Tax Guide)). This form serves as verification that you're withholding federal income tax according to the employee's instructions and needs to be available for inspection should the IRS ever request it. Form W-4 is still subject to review. You may be directed (in a written notice or in future published guidance) to send certain Forms W-4 to the IRS. You must be able to supply a hardcopy of an electronic Form W-4.
https://www.irs.gov/taxtopics/tc753.html