Sally’s column Friday
The IRS's Old 1099 E-File System Shuts Down Nov. 19. Here's Who Has to Move to IRIS
The FIRE system stops taking information returns at 3 p.m. Eastern on Nov. 19, and the 1099s you file in early 2027 have to go through IRIS instead. Most small businesses won't notice. Those that upload their own files will.
- Form 1099
- IRIS
- FIRE
- information returns
- e-filing
- IRS
- small business compliance
At 3 p.m. Eastern on Thursday, Nov. 19, the IRS will stop taking information returns through FIRE, the decades-old system that many businesses and their bookkeepers use to upload 1099s [1]. The 1099s you send for 2026 payments, due in early 2027, will have to go through a newer system called IRIS instead [1]. If a payroll company or accounting software files for you, this is mostly their problem. If someone in your office uploads the files, it’s yours.
What the IRS announced on Aug. 24
The IRS release, IR-2026-99, lays out three cutoffs [1]:
- Nov. 1, 2026: last day to send test files through the FIRE Trading Partner Test System.
- Nov. 9, 2026: last day to change an Information Returns application for a Transmitter Control Code, or TCC. That’s the ID number that lets you send files to the IRS.
- Nov. 19, 2026, at 3 p.m. ET: last day to file anything through FIRE.
After the November maintenance window, FIRE is done, and current FIRE users “must transition to IRIS to file tax year 2026 information returns during the 2027 filing season” [1].
None of this is a surprise to software vendors. A July 2025 IRS bulletin set the 2027 filing season as the target and said IRIS would be the only intake system for returns FIRE now receives [2]. What’s new is the hard date.
What IRIS is, in plain English
IRIS stands for Information Returns Intake System. It has two doors [1]:
- The IRIS Taxpayer Portal, a free website where you can e-file up to 100 returns at a time, by typing them in or uploading a CSV file (a spreadsheet saved in a plain format). You can also download copies for payees and keep a record of what you filed.
- IRIS Application to Application, or A2A, for software that sends large batches directly.
IRIS opened in 2023 and has been taking over forms from FIRE in phases; starting in 2027, every form FIRE handled will be in IRIS [1].
The portal exists because Congress asked for it. The Taxpayer First Act, signed July 1, 2019, told Treasury to offer by Jan. 1, 2023 a website where people could prepare and file Forms 1099, prepare copies for recipients and keep records [4]. The law also says those online services are “a supplement to, and not a replacement for,” other IRS services [4].
Wait, do I even have to e-file?
That depends on a number Congress also changed. The same 2019 law cut the count of returns you can file on paper before e-filing becomes mandatory, from 250 to 10 for calendar years after 2021 [4]. Treasury’s final regulations put the 10-return line into effect for returns due on or after Jan. 1, 2024, and added a twist: you count returns across types, not form by form [3]. Forms W-2 and 1099 go into the same pile [3].
The IRS’s own example: a hypothetical partnership that files eight Forms 1099-MISC and five Forms 1099-INT has 13 returns and must e-file all of them [3].
Small businesses didn’t all welcome this. Two commenters on the 2021 proposal objected to the 10-return line, one calling it “unnecessary and lacks empathy for the challenges facing small businesses,” and another saying some small owners have little understanding of the internet [3]. Treasury and the IRS answered that e-filing had become “more common, accessible, and economical,” and said they’d keep granting hardship waivers and expected the IRIS portal to bring costs down [3]. Treasury estimated at the time that low-volume filers could e-file for about $3.25 a form through commercial services [3].
Does this apply to you? Three hypotheticals
Hypothetical one: an HVAC contractor with seven employees and four subcontractors. That’s seven W-2s plus four Forms 1099-NEC, or 11 returns, so it must e-file [3]. If its payroll provider handles the W-2s and its accounting software sends the 1099s, the owner’s job is a single question to the vendor: are you filing through IRIS for tax year 2026? If the office manager has been uploading the 1099 file to FIRE with the company’s own TCC, she needs an IRIS TCC before January [1].
Hypothetical two: a freelance designer who paid three contractors. Three returns is under the line, so paper is still allowed [3]. She can also use the free portal, which produces the payee copies and keeps a record of what she filed [1].
Hypothetical three: a bookkeeper who files for a dozen small clients through FIRE. This is who the IRS release is really aimed at. Her options are the portal, using CSV uploads, or A2A software [1]. Ice Miller notes the portal takes CSV files and doesn’t require XML, while A2A takes only XML [5]. The firm also warns that IRIS checks files more strictly: “Minor errors that might have been overlooked before may cause a rejection now” [5].
What doesn’t change, according to Ice Miller: which payments you report, and the dates returns and payee statements are due [5].
Is anyone left out?
Nobody loses the ability to file. My worry is the owner who does this alone, once a year, and finds the old login gone in January. TD 9972 leaves a backstop for them: the IRS can waive the e-file requirement for undue hardship, and filers ask on Form 8508 [3]. The main factor is how much more e-filing costs than paper [3].
Readers of my July column on the Senate IRS bill will remember it carried its own e-filed information return deadline proposal. That’s a separate track. This change needs no vote; the IRS is simply turning off one system.
What to do this fall
Start by finding out who actually sends your 1099s. If it’s a vendor, get the IRIS answer in writing. If it’s you, apply for the IRIS TCC now; the IRS lists that as the first step [1]. Ice Miller describes the IRIS code as a five-character alphanumeric identifier, separate from your FIRE code [5].
Then do a dry run. The IRS holds IRIS Working Group meetings on the second Wednesday of each month, and posts updates through IRIS QuickAlerts, which anyone can subscribe to [1]. A practice upload in October costs you an afternoon. A rejected file in late January costs more.
What I’m keeping an eye on
Nov. 19 at 3 p.m. If the IRS moves the cutoff, it will say so through QuickAlerts first [1].
Corrections. The IRS hasn’t said in the Aug. 24 release how you’ll fix a 1099 you originally sent through FIRE once FIRE is gone [1]. That’s the next answer owners and bookkeepers need.
— Sally