IRIS Migration Checklist: 10 Steps Before FIRE Goes Dark

The IRS FIRE system shuts down December 31, 2026. After that, every electronic information return – 1099s, W-2s, ACA forms – must go through IRIS, the Information Returns Intake System. That gives you roughly eight months to make the switch.

Eight months sounds like plenty of time. But between TCC application delays, system testing, internal approvals, and the reality of Q4 workloads, it goes fast. This checklist breaks the migration into 10 concrete steps you can work through now – while there’s still room to plan instead of panic.

Step 1: Audit Your Current FIRE Workflow

Before you can migrate, you need to understand what you’re migrating from. Document every system and process that touches FIRE:

• Which systems generate your FIRE-format flat files? (ERP, payroll, custom scripts, accounting software)
• Who uploads files to FIRE? Is it one person or a team?
• What forms do you file through FIRE? (1099-NEC, 1099-MISC, 1099-K, W-2, etc.)
• How many returns do you file annually?
• Do you file corrections through FIRE?
• Do you handle state filing through FIRE’s Combined Federal/State program?

This inventory is your roadmap. Every item on it needs to work through IRIS (or a provider) by January.

Step 2: Decide Your Filing Method

You have three paths forward after FIRE. Each has different requirements and lead times:

For most businesses, using a filing provider like BoomTax is the fastest and lowest-risk path. You avoid the TCC application, XML development, and testing – the provider handles all of that. But if you want to file directly, start Steps 3-5 immediately.

Step 3: Apply for Your IRIS TCC (If Filing Direct)

If you’re going the DIY route, you need an IRIS Transmitter Control Code. This is separate from your FIRE TCC – it does not transfer.

The application is online through the IRS’s IRIS registration portal. Processing takes up to 45 days, and that’s under normal conditions. As the December deadline approaches, expect longer wait times as applications surge.

Apply now. Not in September. Not in November. Now. A TCC application costs nothing, and having it approved early gives you months to test.

Step 4: Understand the IRIS XML Format

FIRE used fixed-width flat files defined in IRS Publication 1220. IRIS uses XML schemas that are structurally different. If you’re building a direct IRIS integration, your development team needs to:

• Review the IRIS XML schema specifications from the IRS
• Map your existing data fields to IRIS XML elements
• Handle the differences in record structure (IRIS uses nested XML vs. FIRE’s sequential flat records)
• Implement proper XML validation before submission

This is a non-trivial development effort. Budget at least 4-8 weeks of developer time for the initial build, plus testing.

Shortcut: If you use a filing provider like BoomTax, you can skip this step entirely. You can even keep uploading FIRE-format files – BoomTax converts them to IRIS XML automatically.

Step 5: Test in the IRIS Sandbox

The IRS provides an IRIS testing sandbox where you can submit test files without affecting live data. Use it. Extensively.

What to test:

• Basic submission with a small batch of test returns
• Large batch submissions matching your production volumes
• Error handling – intentionally submit bad records to see how IRIS reports errors
• Corrections submissions
• Status polling and retrieval

Do not wait until January to discover that your XML has issues. Testing in the sandbox during Q2 or Q3 gives you time to iterate without deadline pressure.

Step 6: Update Your Internal Documentation

This is the step everyone forgets. Somewhere in your organization, there are process documents, SOPs, or tribal knowledge about “how we file 1099s.” That documentation references FIRE. Update it:

• Replace FIRE URLs and login instructions with IRIS equivalents (or provider instructions)
• Update file format specifications if you’re switching to XML
• Document the new submission process step by step
• Update error resolution procedures – IRIS error codes differ from FIRE’s
• Note any changes to your corrections workflow

If your “filing expert” is on vacation in January, someone else needs to be able to pick up the process. Updated docs make that possible.

Step 7: Confirm State Filing Requirements

If you file with state agencies, the FIRE-to-IRIS switch affects your state filing too. The IRS’s Combined Federal/State Filing (CF/SF) program continues under IRIS, but the mechanics are slightly different.

Check whether:

• Your states participate in the CF/SF program through IRIS
• Any states require separate direct submissions outside CF/SF
• State-specific formatting requirements have changed

BoomTax handles state filing automatically for all supported states, including both CF/SF and direct state submissions.

Step 8: Plan Your Corrections Workflow

Corrections are often an afterthought, but they’re critical. After January 31, you’ll inevitably need to file corrected returns – wrong TINs, wrong amounts, voided forms. Under FIRE, you submitted correction files the same way as originals. Under IRIS, the corrections process is different.

Make sure your migration plan includes:

• Understanding IRIS’s correction submission format
• Testing corrections in the sandbox
• Updating your internal process for identifying and submitting corrections

Step 9: Brief Your Team and Stakeholders

Everyone involved in year-end filing needs to know about this change. That includes:

• Accounting/Finance: They need to know the filing process is changing and what (if anything) they need to do differently
• IT/Engineering: If you’re building a direct integration, they need it on their roadmap now – not in Q4
• Compliance: They should verify that the new process meets all regulatory requirements
• Management: Budget decisions – if you’re engaging a provider or funding a development project, approvals take time

A 15-minute briefing now prevents a fire drill in December.

Step 10: Do a Dry Run Before November

Whatever path you choose – direct IRIS filing, provider, or a hybrid – do a full dry run before November 2026. Take last year’s filing data, run it through your new process end to end, and verify that:

• Data gets into the system correctly
• Validation catches the right errors
• Submissions process successfully (sandbox for direct filers, test submissions for providers)
• Status tracking works as expected
• Your team knows each step of the new process

A dry run in September or October gives you two months of buffer before the January filing deadlines hit. A dry run in December gives you panic.

Frequently Asked Questions

What happens if I’m not ready by December 31?

FIRE shuts down regardless. If you haven’t completed your migration, your fastest option is to sign up with a filing provider like BoomTax – no TCC needed, no XML development, and you can be filing within minutes of creating an account.

Can I use both FIRE and IRIS during 2026?

Yes. Throughout 2026, both systems are operational. This is your window to test IRIS with real submissions while FIRE remains available as a fallback. Take advantage of this overlap period.

How much does IRIS direct filing cost?

IRIS itself is free – the IRS doesn’t charge for submissions. However, building and maintaining an IRIS integration has real development costs. The IRS’s free online portal is also free but only practical for very small volumes.

Does this affect paper filing?

No. The FIRE shutdown only affects electronic filing. However, the IRS now requires e-filing for anyone submitting 10 or more information returns, so paper filing is only an option for very small filers.

What forms are affected?

All information returns currently filed through FIRE: 1099 series (NEC, MISC, K, INT, DIV, R, B, and more), W-2, 1095-B, 1095-C, 1042-S, and others.

Start Today, Not Tomorrow

This checklist isn’t theoretical. Every step is something you can start this week. The IRIS migration doesn’t have to be painful – but it does have to happen. Businesses that start now will barely notice the transition. Those that wait until Q4 will feel every day of it.

If you want the simplest possible migration, create a free BoomTax account and cross most of this checklist off in a single afternoon. No TCC. No XML. No system changes. Just upload your data and file.

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