What is IRIS and how do you file 1099s now?

Last updated: 2026-09-22
The IRS is retiring the FIRE system. The last day to file information returns through FIRE is 19 November 2026 at 3 p.m. ET, and from 1 January 2027 the Information Returns Intake System is the only electronic filing channel, including for prior-year returns and corrections. An existing FIRE Transmitter Control Code does not carry over. Sovos is IRIS-compliant and began filing through IRIS in 2026.

What changed most recently
On 24 August 2026 the IRS issued reminder IR-2026-99 confirming the transition timeline and the November cutoff dates. The IRS has stated it has not announced any extension or delay.

6d8c1a9b-f56d-42b0-aae7-d2279ac342fc

Published By
Sovos

6d8c1a9b-f56d-42b0-aae7-d2279ac342fc
As of
October 20, 2026
72f4c884-23ff-4bd8-8813-2b02eb15e4a5
Author
Charles Maniace
Vice President, Regulatory Analysis & Design
Change Retirement of the FIRE system and mandatory transition to IRIS
Authority Internal Revenue Service
Last FIRE filing 19 November 2026 at 3 p.m. ET
IRIS mandatory from Tax year 2026 returns filed in the 2027 filing season
Affects Forms 1099 series, 1042-S, 1098, W-2G, 5498, 3921 and 3922, and other returns previously filed through FIRE
Required credential A new IRIS Transmitter Control Code. Existing FIRE TCCs do not transfer
E-file threshold 10 or more information returns in aggregate across form types

What does the change require?

FIRE has been the electronic channel for information returns for four decades. IRIS replaces it entirely. Three things follow for any filer that uses FIRE today.

  • A new credential. An IRIS Transmitter Control Code must be obtained through a separate IRIS Application for TCC. An existing FIRE TCC does not work with IRIS and does not carry over.
  • A new format. IRIS receives returns in XML, where FIRE used the Publication 1220 flat file. The XML schema separates fields that FIRE combined, including first, middle, last and business name.
  • A new channel decision. IRIS accepts returns through the IRIS Taxpayer Portal or through IRIS Application to Application, and the choice determines what preparation is required.

Filers who submit through a third-party transmitter file under that transmitter’s production TCC and do not apply for their own.

When do the deadlines apply?

Milestone Date What applies Source
IRIS available 2023 IRIS became available as part of a phased transition of forms from FIRE IRS
New FIRE TCC applications close 2026 The IRS stopped accepting new Information Returns Applications for FIRE Transmitter Control Codes IRS, FIRE system page
FIRE test system closes 1 November 2026 Last day to file test information returns through the FIRE Trading Partner Test System IRS reminder IR-2026-99, 24 August 2026
TCC application changes close 9 November 2026 Last day to make changes to Information Returns Applications for TCC, after which they become read-only IRS reminder IR-2026-99, 24 August 2026
FIRE stops accepting returns 19 November 2026, 3 p.m. ET Last day to file information returns through FIRE, including late and corrected filings IRS reminder IR-2026-99, 24 August 2026
IRIS becomes the only channel 1 January 2027 IRIS is the only electronic filing system for information returns, covering current year, prior year and corrections IRS, FIRE system page
First mandatory IRIS season Early 2027 Tax year 2026 information returns must be filed through IRIS IRS

The pressure point is not the November cutoff itself. It is that the cutoff lands roughly six weeks before tax year 2026 returns come due in January 2027, which removes the usual margin for discovering a problem during the season. 

What are the IRIS filing channels?

Channel What it is Who it suits
IRIS Taxpayer Portal A free web-based system allowing manual entry or CSV upload, filing up to 100 returns at a time, with payee copies downloadable and records retained Lower-volume filers without third-party software
IRIS Application to Application (A2A) A machine-to-machine channel for larger volumes, used by third-party software and by filers who develop their own Mid-market and enterprise filers, and anyone filing at volume

Filers using A2A should test through the IRIS Assurance Testing System with a test TCC before the filing season, because a schema or transmission problem discovered in January is a problem with no remaining runway. Portal filers should validate CSV formatting in advance for the same reason.

What about state filing?

This is the part most often missed. The federal transition does not change state filing, and most states have not adopted the IRIS XML schema. Many continue to accept information returns in the Publication 1220 flat-file format that FIRE used.

The practical consequence is that a filer may need to produce both outputs for the same population: XML for federal submission through IRIS, and 1220 flat file for the states that still require it. An organization planning its transition around federal filing alone can arrive at the season with no state output.
State obligations also differ in kind. Some states receive data through the Combined Federal/State Filing program, others require direct filing, and 1099-NEC is excluded from the Combined Federal/State Filing program entirely.

What are the consequences of not transitioning?

There is no penalty for failing to transition as such. The exposure is that after 19 November 2026 there is no alternative channel, so a filer without an IRIS TCC and a working submission path cannot file electronically at all.

The penalties then follow from the returns themselves rather than from the system change. Electronic filing is mandatory for any filer submitting 10 or more information returns in aggregate across form types, and penalties apply per return for late or incorrect filing, escalating with delay.

What do businesses need to change?

  • Apply for an IRIS TCC, if filing directly. Processing takes time, and applications submitted close to the season leave no margin.
  • Confirm who files. If a payroll provider, accounting firm or software vendor transmits on your behalf, confirm in writing that they are filing tax year 2026 returns through IRIS and that their TCC is in place.
  • Map to XML. The IRIS schema separates name fields that FIRE combined, so source data that was adequate for a flat file may not populate the XML correctly.
  • Test before the season. A2A filers should test through the Assurance Testing System; portal filers should validate CSV formatting.
  • Keep a 1220 path for states. Most states have not adopted IRIS XML, so the flat-file output is still required for state filing.
  • Fix payee data. The transition is a natural point to resolve missing or stale W-9 documentation, which is the underlying cause of most 1099 problems regardless of channel.

How does Sovos support the IRIS transition?

Sovos is IRIS-compliant and began filing through IRIS in 2026, ahead of the FIRE retirement, and is recognized by the IRS as a Modernized e-File business provider. Filers submitting through Sovos file under the transmitter arrangement rather than applying for their own TCC, and Sovos maintains both federal IRIS submission and the state filing paths, including Combined Federal/State Filing and direct state reporting.

Product specifications are published on the Sovos Form 1099 reporting page rather than repeated here.

Frequently Asked Questions

When exactly does FIRE shut down?

The last day to file information returns through FIRE is 19 November 2026 at 3 p.m. ET, including late and corrected filings. From 1 January 2027 IRIS is the only electronic filing system for information returns, covering current year, prior year and corrections.

Does my existing FIRE TCC work with IRIS?

No. An IRIS Transmitter Control Code is a separate credential obtained through a separate IRIS Application for TCC. Filers who submit through a third-party transmitter file under that transmitter’s production TCC and do not need to apply.

What is the difference between the IRIS Portal and A2A?

The IRIS Taxpayer Portal is a free web-based channel allowing manual entry or CSV upload of up to 100 returns at a time. IRIS Application to Application is a machine-to-machine channel for larger volumes, used by third-party software and by filers who build their own. A2A is the usual path for mid-market and enterprise filers.

Does the IRIS transition change state filing?

No, and that is the trap. Most states have not adopted the IRIS XML schema and still accept the Publication 1220 flat-file format. A filer may need both outputs for the same population: XML for federal, flat file for states.

Which forms move to IRIS?

Beginning in 2027, all forms previously supported by FIRE are available through IRIS, including the 1099 series and 1042-S. Form 1099-DA for digital assets was built exclusively on IRIS and was never supported on FIRE.

What happens if we are not ready by November?

There is no alternative channel after 19 November 2026. A filer without an IRIS TCC and a working submission path cannot file electronically, and electronic filing is mandatory for anyone submitting 10 or more information returns in aggregate. Penalties then follow from the returns rather than from the system change.