There’s a pattern we’ve been watching since early 2026: the biggest filers aren’t waiting. Companies filing 10,000+ information returns – payroll providers, banks, insurance companies, large accounting firms – started their IRIS migrations months ago. Some have already completed them.
Meanwhile, thousands of mid-size businesses are still operating on the assumption that December is far away. It’s not. And the organizations that move first are going to have a significantly smoother experience than those that scramble in Q4.
Here’s why early movers have the advantage – and what it means for you.
The Math Favors Moving Early
The FIRE-to-IRIS transition timeline has some hard constraints that punish procrastination:
- TCC approval: up to 45 days. If you apply in November, you might not have your IRIS TCC until mid-January – past the 1099-NEC deadline.
- XML development: 4-12 weeks. If you’re building a direct IRIS integration, that’s development, testing, code review, and deployment. Not something to start in December.
- Sandbox testing: 2-4 weeks minimum. The IRIS testing environment is essential for catching schema issues before they become rejected filings.
- IRS processing capacity. Everyone filing through IRIS for the first time in January creates unprecedented volume. Early movers will have already shaken out their workflows.
Add these up and the timeline is clear: organizations that start now have room for mistakes, iterations, and learning. Organizations that start in October have room for panic.
What Early Movers Get That Late Movers Don’t
1. Time to Test With Real Data
Right now, both FIRE and IRIS are running in parallel. That means you can submit through IRIS and still have FIRE as a fallback. This dual-availability window is the safest time to validate your new workflow with real returns. After December 31, there’s no safety net.
Large filers are using this window to run parallel submissions – filing through their new IRIS workflow while verifying results against FIRE. By January, they’ll have months of production data confirming everything works.
2. Priority Support and Attention
Whether you’re using a provider or working directly with the IRS, support capacity is finite. Right now, filing providers have bandwidth to help with onboarding, data mapping, and test submissions. In December and January, every provider’s support queue will be overwhelmed by last-minute migrations.
The same applies to the IRS itself. TCC applications submitted in June get processed during a calm period. Applications submitted in November compete with a wave of deadline-driven requests.
3. Leverage in Vendor Negotiations
Businesses shopping for filing providers in June have options. They can evaluate, compare, negotiate pricing, and run trials. Businesses shopping in December take what’s available. When you’re facing a January 31 deadline and your old system no longer works, “competitive evaluation” isn’t realistic – you’re buying whatever solves the problem fastest.
4. Internal Alignment Time
Getting budget approval, IT sign-off, security review, and vendor onboarding takes time in any organization. Starting now means these internal processes happen at a normal pace. Starting in Q4 means emergency procurement – faster but more expensive and more stressful for everyone involved.
The Risk of Waiting: A Realistic Scenario
Let’s walk through what happens to a mid-size payroll company that decides to deal with the FIRE migration “later”:
This isn’t hypothetical. This is the trajectory for any organization that starts after summer ends. The FIRE discontinuation FAQ covers what happens when you miss the transition – it’s not pretty.
What “Moving Now” Actually Looks Like
Moving early doesn’t mean a massive IT project. For most organizations, it means one of two things:
If You’re Going Direct
Apply for your IRIS TCC today. While waiting for approval, start building your XML output against the IRS schema. Once your TCC arrives, begin sandbox testing. Aim to have a working integration by September so you can do live parallel testing alongside FIRE in Q4.
If You’re Using a Provider
Sign up, do a test upload, and confirm your data flows correctly. With BoomTax, this takes about 15 minutes. You can upload a FIRE-format file right now, see it parsed into individual returns, and verify everything looks right. When January comes, you upload for real – same process, same file, same result.
Industries Leading the Migration
The organizations moving fastest tend to share common characteristics: high volume, regulatory sensitivity, and long procurement cycles.
If your organization is in one of these sectors and hasn’t started planning, you’re behind your competitors. Not by a little – by months.
The Cost of Being Late
IRS penalties for late information returns are not trivial. And “late” doesn’t mean you forgot to file – it means you filed after the deadline, even by one day:
For a company filing 5,000 returns, being even a month late costs $300,000 in penalties. Being caught without a working IRIS workflow when FIRE shuts down isn’t an inconvenience – it’s a financial risk that dwarfs any migration cost.
Frequently Asked Questions
We only file 500 returns. Is this really urgent for us?
The urgency depends on your workflow, not your volume. If you upload FIRE flat files directly, yes – you need a new plan before December. If you use a provider that’s already IRIS-ready, confirm with them and move on. But don’t assume it’s handled – verify.
Can we file through both FIRE and IRIS during 2026?
Yes. Both systems are operational through December 31, 2026. This is exactly why early movers have an advantage – they can validate IRIS while FIRE is still available as backup.
What if our filing provider hasn’t mentioned IRIS?
Ask them directly: “Are you filing our returns through IRIS?” If they can’t give you a clear yes with specifics, it’s time to evaluate alternatives. The best IRIS filing software options are already certified and submitting through IRIS today.
Our IT team says they need 6 months. Is that realistic?
For a ground-up IRIS integration, 6 months is realistic and potentially optimistic. That includes TCC application (45 days), development (8-12 weeks), sandbox testing (2-4 weeks), and production validation. If you haven’t started, consider using a provider for this filing season and building your direct integration for 2028.
Stop Planning to Plan
The organizations that will have the smoothest transition are the ones that started already. But starting today still puts you ahead of the majority. The FIRE end-of-life checklist is a good starting point for understanding the full scope.
If you want to be filing-ready today – not after a development project, not after TCC approval, not after sandbox testing – BoomTax is the fastest path. Create an account, upload your data in any format, and we handle the IRIS submission.
Get started with BoomTax for free – be IRIS-ready in 15 minutes, not 6 months.
BoomTax, The Boom Post, and its affiliates do not provide tax, legal or accounting advice. This material has been prepared for informational purposes only, and is not intended to provide, and should not be relied on for, tax, legal or accounting advice. You should consult your own tax, legal and accounting advisors prior to engaging in any transaction.
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