2026 Form 1099 / 1042-S Reporting Checklist for IRIS
A practical guide to preparing for the FIRE-to-IRIS transition
For 2026 information returns, the IRS is shutting down the FIRE system, requiring all information returns to be filed through IRIS.
IRIS is a significantly different system — it reviews not only data fields but the data itself, requiring new steps and new processes. System requirements should be reviewed and implemented now, not during the reporting season.
In addition, the IRS has raised the reporting threshold for most Forms 1099 from $600 to $2,000.
This checklist will help you prepare. It is organized into two paths: one for businesses filing directly to the IRS through IRIS, and one for businesses relying on a third-party vendor to manage their filings.
How will you file your 2026 information returns?
Direct electronic filing through IRIS
Manual data entry — Type recipient information directly into IRIS.
CSV submission — Complete an Excel file with recipient information and submit as a CSV. Each file holds up to 250 recipients; multiple files may be submitted.
Application-to-Application (A2A) — Submit returns via API with no limit on the number of recipients.
Third-party electronic filing
Businesses can utilize third-party providers who typically use the A2A process.
Paper filing
Allowed if the filer has fewer than 10 information returns (all return types consolidated for the count).
Alternatively, a hardship request can be submitted to the IRS to request paper filing where electronic filing presents a genuine burden.
Section 1: In-house direct filing path
If filing directly to the IRS, work through the following steps:
Secure an IRIS TCC — Apply for a Transmitter Control Code via the IRIS portal. FIRE TCCs do not work with IRIS, and a separate TCC is required for portal access (manual/CSV) versus A2A filing.
Rebuild ERP data formats — Map ERP outputs to IRIS schema specifications. Update the $2,000 reporting threshold and any internal backup withholding rules previously set at $600.
Incorporate individual name field changes — Re-architect data fields to align with IRIS's strict name parsing rules to avoid systemic validation errors.
Establish direct state connections — Identify non-participating Combined Federal/State Filing (CFSF) jurisdictions and build custom templates for direct state submissions.
Develop software for MeF platforms — Form 945 (backup withholding) and Form 1042 (foreign payments consolidated return) are filed through the Modernized e-File (MeF) platform, which requires dedicated software development.
Manage internal extension requests — Develop a process for IRS and recipient form extensions. Electronic extensions are available in IRIS; fax capability is still required for recipient extensions.
Develop Name/TIN matching — Obtain IRS access for real-time or bulk Name/TIN matching to reduce downstream B-Notices.
Create a certificate collection process — Build an automated or manual process to collect, track, and validate Forms W-9 and the W-8 series.
Section 2: Outsourced vendor path
If using a third-party provider, verify the following before the filing season begins:
Verify IRIS integration status — Confirm the vendor has fully upgraded their infrastructure to transmit directly into the IRIS portal.
Validate provider credentials — Cross-reference the vendor against the IRS recognized IRIS provider list. Note: the list is not fully exhaustive; direct verification with the vendor's technical team is advised.
Confirm vendor TCC activation — Verify the provider has obtained and tested an active TCC configured for 2026 IRIS production filing.
Obtain vendor file schema — Ensure your IT department has the vendor's updated file layout to prevent year-end format mismatches.
Execute pricing analysis — Review updated contract and per-form costs; many providers have significantly increased fees due to the IRIS compliance overhaul.
Assess integrated Name/TIN matching — Confirm the vendor provides real-time or bulk Name/TIN matching to mitigate downstream B-Notices.
Verify MeF platform support — Ensure the vendor can file Form 945 and Form 1042 via MeF, not just individual information returns.
Confirm statutory extension support — Verify the vendor's platform supports electronic preparation and transmission of filing extensions.
Review certificate collection process — Evaluate whether the provider automates collection, tracking, and validation of Forms W-9 and the W-8 series.
Audit CFSF support — Verify the vendor handles automated reporting for states participating in the Combined Federal/State Filing program via IRIS.
Confirm direct state filing fail-safes — Ensure the vendor files independently for states that do not participate in CFSF or form types excluded from the program.
Have questions about your specific situation?
The FIRE-to-IRIS transition involves a lot of moving parts and the right approach depends on your filing volume, vendor setup, and internal systems. If you'd like to talk through what this checklist means for your organization, reach out directly.
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