IRS Transition from FIRE to IRIS:
What’s Changing and How Your Business Can Prepare

Intro

The IRS is retiring the long-standing FIRE (Filing Information Returns Electronically) system and replacing it with IRIS (Information Returns Intake System) —a modern platform that relies on XML, stricter validationname and data formatting rules

If your business files Forms 1099, 1098, 5498, or other information returns, this transition will affect you. For many small and mid-sized organizations without dedicated IT teams, building and maintaining IRIS-compliant systems in-house just isn’t realistic.

This page explains:

✤ What’s changing as the IRS moves from FIRE to IRIS

✤ The new technical and compliance requirements

✤ What your business needs to do

✤ How a service provider like eFile360 can handle everything for you - no software, no XML, no API development required

 

What Is IRIS and Why Is the IRS Replacing FIRE?

FIRE has been used for decades to e-file information returns using a flat-file (1220) format. It worked, but it has limits: older technology, limited validation, and less structure.

IRIS, by contrast, is built to:

✤ Use XML-based schemas instead of flat file

✤ Validate data more rigorously and more quickly

✤ Improve security and identity verification

✤ Support both a web portal for smaller filers and A2A (Application-to-Application) connections for larger ones

 

The IRS has signaled that FIRE will be retired around the 2027 filing season, making IRIS the primary way to file information returns going forward.

Key Changes Businesses Need to Understand

1. XML Replaces Flat Files

Under FIRE, you could generate text-based 1220 files from Excel, legacy scripts, or accounting systems. With IRIS, the IRS expects XML that conforms exactly to their schemas and business rules. That means:

✤ Specific tag names and hierarchy

✤ Data types and lengths enforced by schema

✤ More detailed validation errors when things don’t match

 

This is a software development problem, not just a formatting problem.

2. New Name and Data Formatting Rules

One of the most visible changes is how names are handled. Under FIRE, you could store a full name in a single field (for example, “John A. Smith Jr.”). Under IRIS, names must be split into separate components:

✤ First Name

✤ Middle Name / Initial (optional)

✤ Last Name

✤ Suffix (Jr, Sr, III, etc.)

 

Systems that currently store only a single “Name” field must be updated to collect, store, and export these parts separately. Similar rules apply to addresses and TIN/name combinations, increasing the need for clean, structured data.

3. Stricter Validation and Real-Time Error Handling

IRIS adds stronger, often near real-time validation for:

✤ TIN and name combinations

✤ Required fields

✤ Field lengths and character sets

✤ Business rule consistency

 

Under FIRE, many issues were discovered later through CP2100 or penalty notices. Under IRIS, errors can cause immediate rejection or “accepted with errors” statuses, which still require follow-up.

This is good for data quality—but it means your system must get things right before submission.

4. New TCC and IRS Registration Requirements

Your existing FIRE Transmitter Control Code (TCC) won’t work with IRIS. You must apply for a new IRIS-specific TCC, and that requires:

✤ A valid EIN

✤ Identity verification through ID.me (or equivalent IRS-accepted process)

✤ Linking your IRIS account to the right roles and permissions

 

Without a new IRIS TCC, you cannot file directly via IRIS, whether through the portal or A2A.

5. A2A and API Complexity for Larger Filers

For organizations filing higher volumes, the IRS encourages use of IRIS A2A, which is a system-to-system interface. This isn’t just an upload screen—it involves:

✤ Building and maintaining an API client

✤ Handling authentication tokens

✤ Packaging and transmitting XML under file size limits (often around 100 MB per upload)

✤ Receiving and processing IRS response messages

✤ Implementing retry and error-handling logic

 

For a small or mid-sized business, this typically requires dedicated developers and ongoing maintenance, which many don’t have.

6. Dual Environments During Transition

While IRIS is rolling out, many states still depend on 1220 flat-file formats or their own portals. For a time, businesses may need to support both:

✤ IRIS XML for federal

✤ Legacy 1220/state formats for state filings

 

This adds another layer of complexity if you try to build and maintain your own solution.

 

What Your Business Needs to Do

Here are the high-level steps to prepare:

1. Confirm whether IRIS applies to you

✤ If you file information returns electronically (1099-NEC, 1099-MISC, 1099-INT, 1099-DIV, etc.), you will be affected.

2. Decide how you will file

✤ IRIS Taxpayer Portal: best for small volumes (up to ~100 forms at a time).

✤ IRIS A2A: best for larger filers but requires XML, API integration, and IRS testing.

3. Apply for an IRIS TCC

✤Go through the IRS registration and ID.me verification process well before filing season.


4. Evaluate your data and systems
✤ Can your existing software generate valid XML?
✤ Do you store names and addresses in the format IRIS requires?
✤ Do you have IT resources to handle schemas, testing, and corrections?


5. Consider partnering with a filing service
✤ If you don’t have in-house developers or want to avoid risk and rework, working with a service provider is usually more efficient and cost-effective.

 

Why Building Everything In-House Is Hard for Smaller Businesses

To implement IRIS internally, you’ll likely need:

✤ Developers familiar with XML and APIs
✤ Time to implement and test schema compliance
✤ Resources to go through IRS Assurance Testing (ATS) for A2A
✤ Ongoing maintenance to keep up with schema and rule changes
✤ Additional support to manage corrections and rejections

 

For many organizations, this is more than a one-time project—it becomes a permanent technical responsibility.

 

How eFile360 Makes the IRIS Transition Easy

Instead of building software, you can let eFile360 handle the entire IRIS process for you. With eFile360, you get:

✅ No software to install
✅ No XML or schema development
✅ No API or A2A coding
✅ We stay aligned with IRS IRIS requirements and updates
✅ We manage validations, corrections, and re-submissions
✅ We offer print, mail, and e-file in one place
✅ Support for 1099-NEC, 1099-MISC, 1099-INT, 1099-DIV, and more

 

You upload your data in an easy format, review your forms, and we take care of filing with the IRS and delivering recipient copies.

 

Stay Ahead of the Change

The move from FIRE to IRIS is coming whether businesses are ready or not. Those who prepare early—and especially those who outsource the technical burden—will have a much smoother experience. If you’d rather not:

✤ Learn XML
✤ Build APIs
✤ Maintain IRS schemas
✤ Deal with TCC, ATS, and error codes

 

…then partnering with eFile360 is the simplest, safest path forward.

 

Ready to make the transition easy?
Visit eFile360.com to get started with worry-free 1099 e-filing—no software required.