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The FIRE to IRIS transition means the IRS stops taking information returns through FIRE at 3 p.m. Eastern time on November 19, 2026, and IRIS becomes the only electronic filing system for information returns from January 1, 2027. Your firm needs an IRIS Transmitter Control Code (TCC) before it can file any 2026 Form 1099 in IRIS, and your FIRE TCC does not carry over.

That makes the FIRE to IRIS transition a credential project first and a software project second. The IRS application can take up to 45 days, every responsible official has to sign it, and the 2026 Forms 1099-NEC are due February 1, 2027. This guide walks through the official dates, how IRIS works, the TCC application and a checklist your team can work through this week.

What the IRS Has Announced About FIRE

FIRE (Filing Information Returns Electronically) has been the main channel for e-filing Forms 1099, 1098, 5498 and W-2G for years. In News Release IR-2026-99, dated August 24, 2026, the IRS told filers to prepare for the system's retirement and said that "Current FIRE users must transition to IRIS to file tax year 2026 information returns during the 2027 filing season."

The FIRE page on irs.gov adds that the IRS is no longer accepting new Information Returns (IR) Applications for TCCs. After January 1, 2027, IRIS will be the only electronic filing system for information returns, and that covers current-year returns, prior-year returns and corrections. The IRS also says that beginning in 2027, every form FIRE supported will be available through IRIS.

There is no parallel run in the 2027 season. A firm that files its clients' 2026 Forms 1099 electronically will file them through IRIS or through a provider that transmits to IRIS.

FIRE Retirement Timeline: The Dates That Matter

The shutdown happens in stages. These are the dates the IRS has published, as of October 2026.

DateWhat happensWhat your firm should do
November 1, 2026Last day to send test files through the FIRE Trading Partner Test SystemFinish any FIRE testing you still rely on
November 9, 2026Last day to change an IR Application for TCC; after this the applications become read-only and are kept for referenceSave the details of your FIRE TCC record
November 19, 2026, 3 p.m. ETLast day to file information returns through FIRESend any remaining late or corrected 2025 returns through FIRE before this cutoff, or plan to file them in IRIS
January 1, 2027IRIS becomes the only electronic filing system for current-year, prior-year and corrected information returnsFile all 2026 returns through IRIS
February 1, 2027Due date for 2026 Forms 1099-NEC and for Forms W-2 sent to the Social Security AdministrationFile and furnish on time

The February 1 date comes from the statutory January 31 deadline in the Form 1099-NEC instructions. January 31, 2027 falls on a Sunday, and the IRS general instructions move a weekend due date to the next business day. Forms 1099-MISC and most other 1099s keep their own later IRS deadlines, which are covered in our guide to IRS 1099-MISC and 1099-NEC filing requirements.

FIRE to IRIS Transition: Why the TCC Comes First

Every e-filer of information returns needs a Transmitter Control Code. The IRIS page on irs.gov describes the IRIS TCC as a "5-digit code" that "identifies your business when you e-file forms" and states that "It can only be used for IRIS." A FIRE TCC will not open IRIS, so every firm needs a new application.

How the IRIS Application for TCC works

The IRS tutorial, Publication 5903, sets out the process:

  • Choose your role. An Issuer files only for the company named on the application. A Transmitter files for its own company and for other businesses, which is the usual role for a CPA firm filing client returns. A Software Developer builds software that sends returns through A2A. You cannot select both Issuer and Transmitter.
  • Pick a transmission method for each role: the Taxpayer Portal, A2A, or both. The IRS issues a separate TCC for each role and transmission method.
  • List at least two Responsible Officials (ROs) and at least two Contacts. Sole proprietorships, S corporations and single-member LLCs need only one of each. You can also add up to two Authorized Delegates.
  • Collect each listed person's SSN or ITIN, date of birth, citizenship status, title, email address and phone number, together with the firm's EIN and legal business name.
  • Make sure each RO and delegate can sign in to the IRS application with their own account.
  • Have every RO sign the Application Submission page with a 5-digit PIN. The IRS will not process the application until the last RO signs.

How long it takes

The IRS page on whether you need to file a Form 1099 says "It may take up to 45 days for processing." Publication 5903 says a typical application is processed within 45 business days. Counting 45 business days from October 27, 2026, and skipping the federal holidays in between, brings you to January 4, 2027. A firm that applies today could still be waiting in early January, only four weeks before the February 1 deadline. Submit the application now and push every RO to sign the same week.

How IRIS Works: Taxpayer Portal Versus A2A

IRIS takes returns through two channels. Your choice depends on volume and on the software your firm already uses.

FeatureIRIS Taxpayer PortalIRIS A2A
CostFree, web basedNeeds IRIS-ready third-party software or your own build
How returns go inTyped in by hand or uploaded from the IRS CSV templateXML transmissions sent system to system
Volume per submissionUp to 100 returns at a timeUp to 100 MB per transmission
TCCTaxpayer Portal TCCA2A TCC (separate code)
Best fitFirms with modest volume per clientFirms and service bureaus filing in bulk

The IRIS page describes A2A as the way to "e-file thousands of returns (up to 100 MB at a time)." Both channels support corrections and automatic extension requests, and IRIS accepts information returns for tax year 2022 and later.

Plan portal work around the 100-return cap, which both IR-2026-99 and the IRIS page state.

Worked example: portal batches for one client

Say a property management client paid 340 contractors $2,000 or more in 2026. At 100 returns per submission, the portal route takes four submissions (100, 100, 100 and 40). That is workable for one client. Spread across 30 clients it becomes a heavy January, and that is the point where firms usually move to A2A through their tax or payroll software. If you are weighing that move, our guide to API integration for accounting workflows covers how system-to-system filing fits into a firm's stack.

Who Must E-File and How Your IRIS Volume Changes

The 10-return rule from T.D. 9972 still applies. If a filer has 10 or more information returns of all types combined in a calendar year, it must file them electronically. The 2026 Form W-2 and W-3 instructions apply the same count to W-2s.

A client with 6 Forms W-2 and 5 Forms 1099-NEC has 11 information returns, so both sets must be e-filed. The W-2s go to the Social Security Administration, which the instructions say must receive them by February 1, 2027. Only the 1099s go through IRIS. Our article on the 2026 Form W-2 redesign covers the form changes on that side. A filer that cannot e-file can ask for a waiver on Form 8508, which the IRS general instructions say should be sent at least 45 days before the due date.

Your IRIS counts will also differ from prior years because the Form 1099-NEC threshold changed. The IRS says: "For payments made in 2026, the reporting threshold is $2,000." It was $600 for payments made before 2026. A client who issued 25 forms last year might issue far fewer for 2026, so rebuild each payee list from 2026 payments rather than copying last year's file. The full set of 2026 limits, including Form 1099-K, is in our explainer on the 2026 1099 reporting threshold, and the Form 1099-K threshold guide covers payment platform reporting.

FIRE to IRIS Checklist for CPA Firms

Work through these steps in order. The first three involve the IRS or other people, so they take the longest.

  1. Submit the IRIS Application for TCC this week. Select the Transmitter role and the methods you plan to use. If you are unsure, request both Portal and A2A so you have a fallback.
  2. Line up your Responsible Officials. Confirm each RO has a working IRS sign-in, has their personal details ready and knows they must sign with a PIN. Missing RO signatures leave an application stuck at "Signature Required."
  3. Ask your software provider about IRIS support. Confirm the product transmits to IRIS through A2A for tax year 2026 and find out which TCC it expects you to enter. Do not wait for the January release notes.
  4. Record your FIRE TCC details before November 9. After that date the FIRE application is read-only. Keep a copy for your files and for any questions about prior-year filings.
  5. Clear the FIRE backlog by November 19. Send late or corrected tax year 2025 returns through FIRE before 3 p.m. ET, or hold them until your IRIS TCC is active.
  6. Rebuild payee lists at the $2,000 threshold. Pull 2026 payments by vendor, apply the Form 1099-NEC rules and flag payees that drop off. Our 1099 checklist for accountants breaks this step down by client.
  7. Clean up TINs before filing. Request Forms W-9 from new vendors now and follow up on missing or mismatched names and numbers. Incorrect TINs lead to IRS notices and, eventually, backup withholding.
  8. Download the IRIS CSV template and test it. Fill it with dummy data for one client so your team learns the formatting rules before the deadline.
  9. Write down the new procedure. Record who signs in, which TCC applies to which channel and how corrections are filed, so filing does not depend on one person.

When to Bring In Help

The FIRE to IRIS transition lands in the same weeks as year-end close and W-2 preparation. One workable split is to set up the TCC and the IRIS procedure in house, then hand the repeatable work, such as W-9 collection, payee list review and CSV preparation, to a support team. If you are considering that split, our article on 1099 outsourcing workflow and automation shows which steps transfer cleanly.

Frequently Asked Questions

When does FIRE stop accepting information returns? The last day to file through FIRE is November 19, 2026, at 3 p.m. Eastern time. From January 1, 2027, IRIS is the only IRS system for electronically filing current-year, prior-year and corrected information returns.

Can I use my FIRE TCC in IRIS? No. The IRS says the IRIS TCC can only be used for IRIS, and FIRE no longer accepts new TCC applications. You need to complete an IRIS Application for TCC, and the IRS issues a separate TCC for each role and transmission method you select.

How long does an IRIS TCC take? The IRS says to allow up to 45 days, and its application tutorial says a typical application is processed within 45 business days. Processing starts only after every Responsible Official has signed, so collect those signatures quickly.

How many returns can I upload through the IRIS Taxpayer Portal? The current IRS guidance allows up to 100 returns per submission, entered by hand or uploaded from the IRS CSV template. Larger volumes are better suited to A2A, which accepts transmissions of up to 100 MB.

Which tax years can I file in IRIS? The IRS says IRIS accepts information returns for tax year 2022 and later. From January 1, 2027, late and corrected returns for those years also go through IRIS, because FIRE will no longer be available.

Next Step

Madras Accountancy supports US CPA firms with information return work, including W-9 collection, payee list review, 1099 preparation and IRIS-ready data files, so your team can focus on review and client conversations during filing season. To talk through your 2026 filing workload, contact our team.

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