The migration from the legacy FIRE system (Filing Information Returns Electronically) to the IRS Information Returns Intake System (IRIS) is not a single switch-flip — it is a multi-year transition that began when IRIS opened for the 2022 tax year and ends when FIRE is retired. The publicly communicated FIRE retirement target is December 31, 2026, which means tax year 2026 returns are the first batch most filers will have to send on IRIS without FIRE as a fallback, with the earliest of those deadlines landing on January 31, 2027 for 1099-NEC. Because a brand-new IRIS Transmitter Control Code takes a minimum of 45 business days to clear, the date that should govern your calendar is the day you start, not the day FIRE goes dark. If your season 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
Most filers mark January 31 on the calendar and assume that is the date to plan around. For the FIRE-to-IRIS move, it is not. The date that should reframe your whole year is the day FIRE stops accepting filings, because once it does, the only path left runs through a system you may not yet be registered to use.
The IRS has confirmed that FIRE is being retired and that IRIS is the path forward for filing information returns electronically. Treat the publicly stated December 31, 2026 retirement target as a firm line you need to be well across in advance, not a date to file against. The reason that line matters so much earlier than it looks is the gap between the two systems: your FIRE files will not upload to IRIS, your FIRE Transmitter Control Code does not carry over, and a fresh IRIS TCC has to clear a suitability review that runs a minimum of 45 business days. Stack those together and the real starting gun fires months before the shutdown. For the wider context of why the change is happening at all, our FIRE-to-IRIS transition guide is the place to begin.
The IRS documents the IRIS Taxpayer Portal in Publication 5717, the Application-to-Application (A2A) channel in Publication 5718, and A2A assurance testing 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.
From 2022 to 2027: How the Switch Actually Unfolded
The transition has been arriving in waves since 2022, and reading it as a sequence makes the pressure points obvious. IRIS did not appear overnight to replace FIRE; the two systems ran side by side for several filing seasons while the IRS widened who could use IRIS and tightened who was allowed to stay on paper. The single change that turned IRIS from optional into unavoidable for most filers was the 2024 drop in the electronic-filing threshold, and the single change still ahead is the FIRE retirement itself. The table below lays out the milestones in order so you can see where you sit in the arc.
| When | Milestone | Why it matters to you |
|---|---|---|
| Tax year 2022 | IRIS opens for A2A and the Taxpayer Portal | IRIS becomes a real alternative to FIRE for the 1099 series. The IRIS schema published for these early years differs from the current one, so a submission built to an old layout will not validate today. |
| Tax year 2024 | Electronic-filing threshold drops to 10 aggregate returns | Under Reg. §301.6011-2 (final 2024), a filer of 10 or more information returns counted across all types must e-file. Paper stops being an escape hatch, so far more filers need an electronic channel. |
| Tax year 2025 | IRIS publishes an updated A2A schema for the new tax year | Prior-year layouts are rejected against the updated schema, so if you build your own XML, the format you used last year will not pass. A2A filers must re-clear Assurance Testing in Publication 5719 after a schema-year change. |
| Through 2026 | Final overlap — FIRE and IRIS both accept filings | This is the window to migrate calmly. You can stand up your IRIS TCC, convert your data, and file a test batch while FIRE still works as a safety net. |
The instinct is to count forward from today and conclude there is plenty of runway. The honest math runs the other way. Begin at January 31, 2027 — the first 1099-NEC deadline you will likely meet on IRIS alone — then subtract the weeks you need to convert files and file a test batch, and subtract the full 45-business-day suitability review on top of that. For most filers the resulting start date sits in 2026, well before the season they are picturing.
The Last Day FIRE Accepts a Filing
The headline date of the whole transition is the FIRE retirement, with December 31, 2026 as the target the IRS has communicated. After that cutover, FIRE is no longer the route for new information-return filings and IRIS is. It is worth being precise about what that does and does not mean, because the date is easy to misread as a deadline you can file right up against.
It does not mean your filings are due on December 31, 2026. Your forms are still due on their normal dates in 2027 — January 31 for 1099-NEC, March 31 for most other 1099-series e-filings, and May 31 for the 5498 series. What the retirement date means is that the tool you used to meet those dates is gone, so the moment FIRE closes, you must already be able to file on IRIS. The danger is treating the shutdown as your start line. If you wait until your usual filing window in early 2027 to discover that your FIRE TCC does not work and your files will not upload, you will be building a brand-new relationship with the IRS under the worst possible deadline pressure.
The First Deadline You Meet on IRIS Alone
Once FIRE retires at the end of 2026, tax year 2026 returns become the first season most filers send entirely on IRIS, and the earliest of those due dates is the one to circle. Because the 1099-NEC filing deadline and its recipient-copy deadline both fall on the same day, there is no slack to absorb a late discovery that your IRIS access is not ready.
| Form (tax year 2026) | IRS e-file due | Recipient copy due |
|---|---|---|
| 1099-NEC | January 31, 2027 | January 31, 2027 |
| 1099-MISC, 1099-K, 1099-INT, 1099-DIV, 1099-R | March 31, 2027 | January 31, 2027 (varies by box/form) |
| 5498 series | May 31, 2027 | Varies |
Two practical notes about these dates. First, any deadline that falls on a weekend or federal holiday shifts to the next business day, so confirm the exact date for your form against the current IRS calendar each year rather than relying on date arithmetic. Second, the spread between the January 31 NEC deadline and the March 31 deadline for most other forms is real breathing room only if your IRIS access already exists — it does nothing for you if you are still waiting out a suitability review. If you want the full breakdown by form, our guide to the 1099 filing deadlines for 2027 walks through every due date.
The form-by-form due dates are published in the due-date chart of Publication 5718 (and mirrored for the portal in Publication 5717). Because the IRS updates these each cycle and applies weekend/holiday shifts, treat the dates above as planning anchors and verify the current year on IRS.gov.
What You Have to Do Differently Before the Window Closes
Knowing the dates is only useful if you map your own work onto them. The sequence below turns the timeline into action, and the one task that dominates everything is the IRS suitability review — so the sooner you reach the application step, the more slack you keep for the conversion and testing that follow.
Confirm where you sit on the timeline
Check whether you crossed the 10-return e-file threshold and which IRIS schema year you are filing into. If you build your own XML, note that each tax year has its own published schema, so last year’s format will not pass against the current one.
~1 hourStand 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 downstream can start until identity proofing is finished, so this is the true beginning.
~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 and choose the channel — 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 45-business-day suitability review
The IRS reviews your organization and each official over a minimum of 45 business days — roughly nine calendar weeks. Submit once and monitor e-Services; 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 (ATS) scenarios in Publication 5719 before the IRS will let them into production.
Days to weeksFile a test batch ahead of the January 31 line
Submit a small, real batch well before the deadline so you can read the acknowledgments and fix any rejects while there is still time, then file the rest comfortably ahead of January 31, 2027.
~1 dayOut of runway on the calendar?
An IRS-authorized provider that already holds an IRIS TCC can file on IRIS for you right now — no new application, no 45-day wait, and no ATS testing on your side.
Common Rejection Reasons (and How to Avoid Them)
A FIRE-to-IRIS migration tends to fail in a handful of predictable ways, and almost all of them cost you the one thing you cannot buy back: time on the calendar. The items below are ordered roughly by how often they bite, so start at the top and work down.
Cause: treating December 31, 2026 as the date to begin, when the 45-business-day suitability review alone runs about nine weeks before you have written a single line of conversion code or filed one test record. Fix: count backward from January 31, 2027, stack the review, ID.me proofing, and conversion time on top of one another rather than assuming they overlap, and start during the 2026 overlap window while FIRE is still a safety net.
Cause: expecting to reuse your existing FIRE Transmitter Control Code on IRIS, even though the two systems are entirely separate with no transfer path between them. Fix: submit a new IR Application for an IRIS TCC through e-Services as early as you can, and treat the old FIRE code as retired.
Cause: building a current-year submission against an older IRIS schema, since each tax year has its own published layout and the updated schema rejects prior-year formats outright. Fix: validate every transmission against the current published schema for the tax year you are filing, and re-clear Assurance Testing in Publication 5719 after any schema-year change.
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 Whole Timeline: The e1099f Advantage
Every date above is yours to manage 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 suitability clock and the schema upgrades stop being your problem. If you would rather not become a registered IRIS transmitter before the FIRE sunset, that is the fastest compliant way to be ready for January 31, 2027.
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, current-schema IRIS XML, so there is no generation logic to rewrite each year.
Always on the right version
We track the IRIS schema year for you, so a new-schema change never becomes your emergency the week filings are due.
If you would rather not register as an IRIS transmitter before the sunset, this is the fastest compliant path to the 2027 deadline — CF/SF included.
Frequently Asked Questions
When is the last day I can file on FIRE?
What is the first deadline I’ll have to meet on IRIS alone?
When did IRIS first become available?
Why did so many filers have to move to IRIS in 2024?
Does my FIRE TCC work for IRIS?
How long does getting IRIS access take?
Can I just keep using FIRE until the very last day in 2026?
Do the deadlines shift if they fall on a weekend?
Did the IRIS XML format change over the timeline?
Will IRIS still support Combined Federal/State Filing?
Is there a fee to move from FIRE to IRIS?
Do I need to track any of this 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.