The legacy FIRE system (Filing Information Returns Electronically) is sunsetting, and the IRS’s Information Returns Intake System (IRIS) is its replacement for 1099-series filing. The catch is that the two systems share nothing that makes the switch easy: your FIRE files will not upload to IRIS, your FIRE Transmitter Control Code does not carry over, and a brand-new IRIS TCC takes a minimum of 45 business days to clear suitability review. The single biggest risk is treating this as a January task, because by January the calendar has already run out. If your deadline won’t wait, a provider that already holds an IRIS TCC can file for you today.
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The Deadline Behind the Deadline
The date that should reframe your year is not January 31 — it is the day FIRE goes dark. The IRS has confirmed that FIRE is being retired and that IRIS is the path forward for filing information returns electronically, which means that at some point the upload process you have relied on for years simply stops being an option.
Treat the publicly stated December 31, 2026 FIRE retirement target as the line you have to be across well in advance, and do not plan to file right up against it. The two systems are not interchangeable in any meaningful way: there is no conversion utility, there is no “import my FIRE files” button, and there is no way to reuse the credential you have been transmitting under. If you wait until your usual filing window to discover all of that, you will be building a fresh relationship with the IRS under deadline pressure — which is the worst possible time to start.
The IRS documents the IRIS Taxpayer Portal in Publication 5717 and the Application-to-Application (A2A) channel in Publication 5718, while A2A assurance testing is covered in Publication 5719. You apply for access through IRS e-Services. Because the IRS can revise program dates, confirm the current retirement timeline on IRS.gov before you plan around it. For the broader picture, start with our FIRE-to-IRIS transition guide.
The Key Dates You Actually Have to Plan Around
The sunset is not a single event so much as a sequence, and the dates that truly govern you sit earlier than the shutdown itself. The most useful way to read the schedule below is backward: the last item is the wall you cannot move, and everything above it is what has to happen before you reach it. Each milestone depends on the one before, so a slip early in the chain pushes everything else into the danger zone.
- Now through Q3 — start your IRIS registration. Create or confirm an IRS e-Services account, complete ID.me identity verification for every official on the application, and submit the IR Application for a brand-new TCC. Nothing downstream can begin until this is in motion.
- Roughly 45 business days — the IRS suitability review runs. That window is about nine calendar weeks and cannot be expedited. A2A filers should use the same stretch of time to build their XML and pass Assurance Testing (ATS).
- Before filing season — reach a ready state. Your TCC is approved, your files are converted, and you have filed a small test batch. This is the position you want to be in comfortably ahead of recipient-copy and e-file due dates.
- December 31, 2026 — the FIRE retirement target. After the cutover, FIRE is no longer the route for new information-return filings; IRIS is. This is the wall, not your start line, so do not plan to file at the wire.
The temptation is to count forward from today and assume you have plenty of runway. The honest math runs the other way. Start from January 31, subtract the weeks you need to convert files and file a test batch, then subtract the full 45-business-day review on top of that, and you arrive at the date you actually have to begin. For most filers that start date is months earlier than instinct suggests.
Who This Hits, and How Hard
The sunset lands differently depending on how you file today, and the closer your current process sits to FIRE’s underlying machinery, the more work the switch becomes. It helps to find yourself in one of the three profiles below before you decide how much runway to budget.
Small businesses and one-off filers
If you file a handful of 1099-NEC or 1099-MISC forms each year, or you have someone do it for you, the change is mostly administrative. You will need an IRIS TCC of your own, or a provider who already holds one, and you will trade FIRE’s fixed-width file for one of three IRIS paths: keying returns directly into the IRIS portal, uploading the IRIS CSV template, or letting filing software produce the submission for you. This profile is painful only if you discover the change in January with no time to react.
Large transmitters and high-volume filers
If you push thousands or millions of returns through FIRE’s flat-file upload, the migration is a genuine project rather than an errand. IRIS A2A speaks XML rather than the position-based FIRE record, so the logic that generates your files has to change; you must pass ATS before you are allowed into production; and the 45-business-day suitability review gates the entire effort. Budget this work in months, not weeks.
Software vendors and service bureaus
If you file on behalf of clients, you are carrying everyone’s deadline at once, which makes timing the hardest part. You need the correct roles on your application — Transmitter, and often Software Developer as well — client consent handled correctly, and a tested A2A pipeline, and all of it has to be ready before your clients’ season rather than your own.
FIRE files are fixed-width records in which a field is defined entirely by its position on the line. IRIS XML is self-describing instead: every value sits inside a named element, so the document itself says what each piece of data means. Because of that fundamental difference, your old files will not upload as-is and the data has to be genuinely re-expressed, not reformatted. For the full picture, see how IRIS compares to FIRE side by side and our walkthrough on converting FIRE flat files to IRIS XML.
Your End-of-Life Checklist, Step by Step
Here is the full migration path in the order you should tackle it. Each step carries a rough time estimate, but the one that dominates the schedule is always the IRS review — so the sooner you reach step four, the more slack you keep for everything that follows.
Inventory what you file today
List every form type you submit, the volume of each, the entities (EINs) you file under, and whether you use FIRE’s portal or its bulk upload. This inventory is what tells you which IRIS channel — portal or A2A — you actually need.
~1–2 hoursStand up IRS e-Services and ID.me
Create or confirm an e-Services account, then complete ID.me identity verification for your Responsible Official and every authorized user. Nothing else can proceed until identity proofing is finished, so this is the true starting gun.
~5–15 min per personSubmit the IR Application for a new IRIS TCC
Because your FIRE TCC does not transfer, you apply for a fresh IRIS TCC, choosing Portal (TP), A2A, or both, along with the roles you file under. The full TCC application walkthrough covers every field you will be asked for.
~1 hourWait out the suitability review
The IRS runs a minimum 45-business-day review of your organization and each official. Submit once and monitor e-Services, because resubmitting does not speed anything up — it only restarts the clock from zero.
45+ business daysConvert your data and, for A2A, pass ATS
Re-express your FIRE data as IRIS XML or in the IRIS CSV layout. A2A filers must additionally clear the Assurance Testing scenarios described in Publication 5719 before the IRS will let them into production.
Days to weeksFile a test batch, then go live
Submit a small, real batch well ahead of the deadline so you can see the acknowledgments and catch any rejects while there is still time to fix them, then file the rest. Keep an eye on the upcoming filing deadlines so the cutover lands comfortably ahead of them.
~1 dayDon’t want to run this whole project yourself?
An IRS-authorized provider that already holds an IRIS TCC can file on IRIS for you — without you standing up your own integration or waiting out the review.
Common Rejection Reasons (and How to Avoid Them)
A FIRE-to-IRIS migration tends to fail in a few predictable ways, and most of them cost you the one resource you cannot buy back: time on the calendar. The items below are ordered roughly by how often they bite, so start at the top.
Cause: treating the switch as a January task, when the 45-business-day suitability review alone runs about nine weeks before you have written a single line of conversion code or filed a single test record. Fix: start now, count backward from January 31, and stack the review, ID.me proofing, and conversion time on top of each other rather than assuming they overlap.
Cause: expecting to reuse your existing FIRE Transmitter Control Code on IRIS, even though the two systems are entirely separate and offer no transfer path between them. Fix: submit a new IR Application for an IRIS TCC through e-Services as early as you possibly can, and treat the old code as retired.
Cause: assuming your fixed-width FIRE files will load into IRIS, when IRIS expects either XML through A2A or its own CSV template rather than the FIRE record layout. Fix: convert the data into an IRIS-accepted format first, or use software that produces validated IRIS output directly from the files you already generate.
Cause: the business name on the IRIS application does not match the name tied to the EIN in IRS records, so the application is rejected and the 45-day clock starts over. Fix: use the exact legal name from your EIN assignment notice (CP 575) rather than a DBA or a shortened trade name.
Skip the Migration Project: The e1099f Advantage
Everything above is required only if you migrate to IRIS yourself. There is a second path: file through an IRS-authorized provider that already holds an IRIS TCC, so the deadline math stops being your problem entirely. If you would rather not become a registered IRIS transmitter before the sunset, that is the fastest compliant way off FIRE.
No 45-day wait
We already hold an IRIS TCC, so you create an account and file today — no new application, no suitability review, and no ID.me proofing on your end.
Keep your FIRE files
Upload the FIRE-format files you already produce and we convert them to validated IRIS XML automatically, so there is no generation logic to rewrite.
Validation built in
Every record is checked against the IRS business rules before submission, and you get a Receipt ID back instead of a rejection code to decode.
If you would rather not register as an IRIS transmitter before the sunset, this is the fastest compliant path off FIRE — CF/SF included.
Frequently Asked Questions
When does the IRS FIRE system shut down?
Can I keep using FIRE until the very last day?
Does my FIRE TCC work for IRIS?
Can I upload my existing FIRE files to IRIS?
How long does getting IRIS access take?
Is there a fee to move from FIRE to IRIS?
Will IRIS still support Combined Federal/State Filing?
What forms does IRIS handle?
What if I started the IRIS application and it was rejected?
Do I need to migrate at all if I file through e1099f?
Not tax advice. This guide is general information about IRS procedures and may change as the IRS updates IRIS and its retirement timeline. Confirm current dates and requirements in the official IRS publications linked above, and consult a tax professional about your situation.