If your firm handles 1099s for clients, the shift from the legacy FIRE platform to the IRS Information Returns Intake System (IRIS) is not just a technology change. It is a workflow change that hits at the exact moment your team is gearing up for tax season. The firms that treat this as a predictable operations upgrade will cruise through January. The firms that treat it as “we’ll figure it out when we file” risk a painful overlap of deadlines, access issues, and avoidable rework.
The IRS has already stated that tax year 2026, filing season 2027 is the targeted retirement window for the FIRE system, and that IRIS will be the only intake system for information returns for filing season 2027. You can read that directly on the IRS FIRE page: Filing Information Returns Electronically (FIRE).
So the real question for CPA and accounting firms is simple: how do you build an IRIS-ready 1099 workflow that does not steal hours from 1040 and business-return production?
What changes when FIRE fades and IRIS becomes the default
IRIS is not “FIRE with a new coat of paint.” It is a modernized intake system with two channels:
- IRIS Taxpayer Portal (UI) for web-based filing
- IRIS Application-to-Application (A2A) for software-based, higher-volume transmission
The IRS describes both channels and the core capabilities on its IRIS overview page: E-file information returns with IRIS.
That matters because many firms have historically relied on an established FIRE process, a specific transmitter setup, and a “we do it this way every year” rhythm. IRIS requires you to revisit a few operational foundations: access, transmitter control codes, file format expectations, and what your team does inside a portal versus inside tax software.
What IRIS is designed to make easier
The IRS positions IRIS as a free e-file solution for information returns with practical features that are directly relevant to CPA-firm workflow. In the IRIS Taxpayer Portal, the IRS notes you can e-file up to 100 returns at a time, enter manually or by CSV upload, download payee copies, and keep a record of completed, filed and distributed forms. That feature list is on the IRS IRIS page:
It is also worth noting that IRIS supports corrections and automatic extension requests, which is particularly useful for firms that want a clean way to handle late vendor data without turning corrections into a separate fire drill.
The IRS newsroom has also highlighted the “free online” aspect of IRIS for Form 1099 series filings, including uploading via templates and handling corrections in the system.
The IRIS TCC detail that firms should not ignore
A common operational surprise is that the IRIS Taxpayer Portal requires an IRIS Transmitter Control Code (TCC). The IRS states this clearly in the “Get started” section of the IRIS page.
For firms used to “we already have a FIRE TCC,” the important nuance is that IRIS TCCs are specific to IRIS. The IRS explains TCC application and options on: IRIS application for TCC.
If you plan to use A2A with software or a third-party service, IRIS A2A has its own setup requirements including the IRIS A2A TCC and an API client ID, which the IRS lists under the A2A section on the IRIS page.
In plain terms: do not make “getting access” a January problem. Make it a pre-season problem.
The real operational impact on CPA firms: the January compression
Even if IRIS makes filing smoother, the time squeeze remains the same. January is already crowded:
- Vendor and contractor cleanup
- W-9 gaps and TIN mismatches
- Client back-and-forth on legal names and classifications
- Internal approvals on who receives payee copies and how distribution happens
- A spike in new tax-season onboarding, organizers, and extension planning
That is why the winning strategy is to treat 1099 work like a small production line with a clear input pack and a clear output pack. The “portal button-clicking” is rarely the hard part. The hard part is upstream data quality.
This is also where firms value stable capacity and predictable communication. As Elizabeth Bergen shared on Finsmart’s testimonials page: “The Finsmart team has always felt like a part of our team. They’re included in our meetings, collaborate seamlessly.”
That “part of our team” feeling is not just culture. For time-bound filings like 1099s, it means fewer handoff gaps, fewer missing fields, and fewer last-minute escalations.
A clean IRIS-ready 1099 workflow that reduces rework
The most effective IRIS transitions start with a simple rule: separate data readiness from filing submission. Your team should not be uploading a CSV while still debating whether a vendor is a 1099-NEC recipient or whether a W-9 is valid.
An IRIS-ready workflow usually has these components:
A payer and payee master list that is reconciled early
Your list of payees should be cleaned before any portal work begins. Names, TINs, entity type, and address format should be consistent. The goal is to prevent “we uploaded, but we failed validation” churn.
A classification decision that is documented
When a client changes how they pay contractors, or a vendor’s status changes, your file should show the “why.” This is not over-documentation. It prevents rework when a client asks questions after payee copies go out.
A single source of truth for totals
Whether you pull totals from QBO, Xero, payroll systems, or spreadsheets, the output should be one consolidated 1099-ready data pack. That pack becomes your review point.
A short internal review gate before submission
Someone should check for obvious errors: missing required fields, mismatched states, duplicate payees, glaring dollar anomalies, and whether corrections from last year have been addressed.
Submission, distribution, and proof of filing as one package
IRIS can keep records and allow downloads. Your firm should still create a standard closeout package: confirmation, payee copies distribution method, and a log of what was filed for which client.
If you want a deeper technical reference for electronic filing specifications, the IRS continues to publish and update Publication 1220, which includes context on the FIRE retirement timeline and IRIS becoming the intake system for filing season 2027.
E-filing threshold pressure is not going away
The IRS has also made electronic filing the default for many filers by lowering the threshold. The FIRE page states that starting tax year 2023, if you have 10 or more information returns, you must file them electronically. That is shown under “E-filing required for 10 or more returns”.
This matters for small and mid-size client books. Firms that previously filed a handful of paper 1099s now need an electronic workflow that is repeatable.
How an embedded seat model helps during the IRIS transition
For many CPA firms, the “IRIS transition” is really a staffing and focus issue. You need reliable hands to:
- clean and validate payee master data
- chase missing W-9s using a consistent script
- build the 1099 data pack and flag anomalies
- prepare CSV uploads in the format your team standardizes
- package proof of filing and client delivery records
Those are structured tasks that benefit from dedicated capacity, especially when your onshore team needs to protect reviewer bandwidth for tax returns.
That is exactly where a seat-based approach is useful. With an embedded model like the Accounting Seat Model, dedicated professionals work inside your workflow and tools. For CPA firms scaling tax delivery, dedicated capacity through US Tax Seats can support prep operations while you keep control of review, client communication, and filing decisions.
When you are changing systems or tightening a January production line, steady execution matters more than flashy promises.
The easiest way to start now
If your firm wants to be ready well before filing season 2027, the smartest move is to run one “practice season” where IRIS becomes your default for a controlled segment of clients. Pick a segment where the payee list is clean and repeatable, then build your internal playbook around that experience. You will surface access requirements, CSV formatting habits, and internal review gates early, while the stakes are lower.
If you want an IRIS transition checklist tailored to your firm’s process, Book a Meeting or email [email protected] with your current 1099 volume (approximate number of forms), your tech stack (accounting system and portal), and whether you plan to file via the IRIS Taxpayer Portal or software. We will share a practical workflow template your team can adopt without slowing down tax season.
In this Article
editor
Maanoj Shah is the Co-founder & Director of Growth Strategy & Alliances at Finsmart Accounting, where he pioneered the “Accounting Seat” model—a revolutionary offshore embedded staffing solution purpose-built for Accounting and CPA firms. Widely recognized as an outsourcing and offshoring expert, Maanoj’s insights have been featured in leading accounting publications, and he regularly speaks at premier industry conferences including Scaling New Heights, Bridging the Gap, BKX, and Women Who Count.
A dynamic growth leader with over two decades of experience, Maanoj has incubated, scaled, and exited ventures across Fintech, HR, and Consulting sectors, holding various CXO roles throughout his career. His passion for scaling businesses is matched by his commitment to social impact. He is the Co-founder of Mission ICU, a national healthcare initiative that installs critical care units in underserved areas of India, and was recognized by the World Economic Forum for its last-mile impact.
Outside of work, Maanoj leads an active lifestyle as an avid tennis player and passionate golfer, blending strategy and agility on and off the court.
CONTENT DISCLAIMER
The content in this article is for general information and education purposes only and should not be construed as legal or tax advice. Finsmart Accounting does not warrant or guarantee the accuracy, completeness, adequacy, or currency of the information in the article. You should seek the advice of a competent lawyer or accountant licensed to practise in your jurisdiction for advice on your particular situation.
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