IRS Publication 1220: FIRE and IRIS Filing Specifications

IRS Publication 1220 sets out the electronic filing requirements for the 1097, 1098, 1099, 3921, 3922, 5498, and W-2G form series, including the exact record layout, the platforms you can use, filing deadlines, and the procedures for corrections and extensions. If you file 10 or more information returns in a calendar year, electronic filing is mandatory, and the penalties for missing deadlines or filing incorrect returns climb quickly. One shift matters before anything else: the IRS has announced that the legacy FIRE system is targeted for retirement after the 2027 filing season, with the Information Returns Intake System (IRIS) becoming the sole electronic intake platform.¹

Who Must File Electronically

Beginning with returns filed in 2024, the electronic filing threshold dropped from 250 returns to just 10. The count aggregates across nearly all information return types, so a business that issues five 1099-NEC forms and five 1099-MISC forms has hit the line and must file electronically.²

The aggregation rule catches filers who used to stay under the old threshold by spreading modest volumes across different forms. A small employer who also pays contractors and reports mortgage interest counts every one of those forms against the 10-return total.

Deadlines for the 2026 Filing Season

Electronic filers generally get an extra month over paper filers, but several forms share the same deadline regardless of method.³

January 31: Form 1099-NEC and Form W-2, paper or electronic.
March 15: Form 1042-S, paper or electronic.
March 31: Forms 1098, 1099-MISC, 1099-DIV, 1099-INT, 1099-B, 1099-R, W-2G, 3921, 3922, and most other 1099 variants when filed electronically. Paper deadline is February 28.
May 31: Form 5498, paper or electronic.

If a deadline falls on a weekend or federal holiday, it shifts to the next business day.

Choosing Between FIRE and IRIS

Two electronic platforms are currently available, and the choice matters because one of them is being retired.

FIRE

FIRE is the legacy platform that Publication 1220 was built around. It accepts fixed-length ASCII text files formatted to a 750-character-per-record specification. Filers log in at fire.irs.gov using their Transmitter Control Code (TCC), EIN, and password. The FIRE production system opened for the 2026 filing season on January 6, 2026.⁴

FIRE is targeted for retirement after the 2027 filing season, so tax year 2026 returns filed in early 2027 may be the last cohort processed through it.

IRIS

IRIS is the replacement platform. It supports the full 1099 series, 1098 forms, 5498 forms, W-2G, 1042-S, and others. Two submission methods are offered: a free Taxpayer Portal where you key in forms through a web interface, and an Application-to-Application (A2A) channel for bulk submissions. The portal is well suited to smaller filers who would rather not deal with ASCII formatting at all.⁵

IRIS requires its own TCC, separate from a FIRE TCC. Transitioning filers apply for a new IRIS TCC through the IRS online application, and each authorized user must have an IRS account verified through ID.me.⁶

If you’re new to electronic filing, IRIS is the better long-term investment. FIRE still works for the current filing season, but building a workflow around a system slated for retirement creates avoidable migration work later.

Getting a Transmitter Control Code

Both platforms require a five-character alphanumeric TCC that identifies the transmitting entity. You apply through the IRS’s online IR Application for TCC, which replaced the old paper Form 4419.⁷

The application asks for your EIN, business details, and contact information. The IRS recommends submitting by November 1 of the year before your filing deadline and allowing up to 45 days for processing. A single TCC can cover returns for multiple payers if you’re acting as the authorized transmitter. FIRE and IRIS TCCs are separate, so filers using both platforms need one of each.

Building a File to Publication 1220 Specifications

This applies to FIRE submissions and to A2A transmissions through IRIS. Filers using the IRIS Taxpayer Portal to enter forms manually don’t need to worry about record layouts.

Every record in the file occupies exactly 750 character positions, and the file is built from a specific sequence of record types.¹

Transmitter “T” Record opens the file with your TCC, transmitter name, and contact details. One per file.
Payer “A” Record identifies the paying entity, with EIN and the specific form type being reported. One for each payer in the file.
Payee “B” Record is the core data. One record per recipient, with TIN, name, address, and payment amounts. This is where most errors occur.
Control Total “C” Record follows each group of “B” records, summarizing recipient count and total dollar amounts for that payer.
End of Transmission “F” Record closes the file with a final count of all Payer “A” records.

Each field within each record has a defined position, length, and format. A name that starts at position 12 and runs 40 characters must occupy exactly those positions, padded with blanks if the actual name is shorter. A single misaligned position throws off the whole file, and FIRE will reject it. This is the most common stumbling block for filers building files without software.

Software

Most filers don’t hand-build these files. The IRS maintains an Authorized E-file Provider Locator that lets you search for software developers participating in the e-file program, though inclusion doesn’t constitute an endorsement.⁸

Payroll and accounting platforms such as QuickBooks, Sage, and ADP typically include 1099 e-filing modules that generate Pub 1220-compliant files. For modest volumes, the free IRIS Taxpayer Portal skips file formatting entirely.

Testing and Submitting Through FIRE

The IRS operates a FIRE test system that mirrors production. First-time filers are encouraged to submit a test file to confirm their software produces correctly formatted output. Testing is optional for general FIRE submissions but mandatory for filers applying to the Combined Federal/State Filing Program.⁹

The test and production systems don’t share data, so separate accounts are required for each. For the 2026 filing season, the test system was available November 6, 2025, went down for annual updates on November 19, and reopened January 5, 2026. Production opened the following day.⁴

To submit, log in at fire.irs.gov with your TCC, EIN, and password. Passwords must be 8–20 characters with at least one uppercase letter, one lowercase letter, one number, and one special character.¹⁰ Select “Send Information Returns,” identify the tax year, and upload the file. The system returns an immediate confirmation number. Processing takes several business days, and the status will come back as accepted, accepted with errors, or rejected. A rejection means the file has to be corrected and resubmitted. Accepted with errors means most records went through but some need correction filings.

Filing Corrections

If the original return was filed electronically, corrections must also be filed electronically. Publication 1220 splits errors into two categories.¹

Type 1 errors involve wrong dollar amounts, codes, or checkboxes. File a single correction with the right information.
Type 2 errors involve a wrong TIN or payee name. These take two steps: submit a correction that voids the original record, then file a new return with the correct information.

Correction files follow the same record layout as originals, but the Payee “B” record must include a correction indicator that identifies the fix type. Corrected returns don’t count toward the 10-return threshold, so a batch of corrections won’t push an otherwise paper-eligible filer into mandatory e-filing.

Extensions and Hardship Waivers

Form 8809 Automatic Extension

Form 8809 requests an automatic 30-day extension for most information return types. No justification or signature is required. Form W-2 and Form 1099-NEC don’t qualify for automatic extensions.¹¹

Submit Form 8809 through FIRE, through IRIS, or on paper. The request has to be filed by the original due date. Late requests are denied automatically. If several form types with different deadlines are involved, file by the earliest due date.

Form 8508 Hardship Waiver

Filers who genuinely can’t meet the electronic requirement can apply for a waiver on Form 8508. The most common ground is undue financial hardship, defined as the cost of electronic filing exceeding the cost of filing on other media. A hardship claim must include current-year cost estimates from two service bureaus or third parties. Prior-year estimates are not accepted, and missing estimates result in automatic denial.¹²

Submit Form 8508 at least 45 days before the due date. Fax is the preferred method (877-477-0572); mail goes to the Extension of Time Coordinator in Kearneysville, West Virginia. The form must be signed by the taxpayer or an authorized representative with a power of attorney on file.

Penalties for Late or Incorrect Returns

Section 6721 of the Internal Revenue Code sets penalties for failing to file correct information returns on time. Amounts adjust for inflation, and for returns due in 2026 the tiers are:¹³

Corrected within 30 days of the due date: $60 per return.
Corrected after 30 days but by August 1: $130 per return.
Filed after August 1 or not filed: $340 per return.
Intentional disregard: $680 per return with no annual cap.

Annual caps limit total exposure for filers who aren’t acting with intentional disregard, and small businesses with average annual gross receipts of $5 million or less get substantially lower caps than larger businesses.¹⁴

For intentional disregard, the penalty is the greater of $680 per return or, for most return types, 10 percent of the total amount that should have been reported, with no annual maximum.¹⁵ A de minimis exception applies when you correct errors on the greater of 10 returns or one-half of one percent of your total returns for the year; no penalty applies to those corrections.

TIN Accuracy and Backup Withholding

TIN problems are the most persistent source of penalties on information returns, and they carry a second consequence. When the IRS notifies you that a payee’s TIN is missing or incorrect, you may be required to begin backup withholding at 24 percent on future payments to that payee.¹⁶

Backup withholding continues until the payee supplies a correct TIN. The IRS TIN Matching program lets authorized filers verify name-and-TIN combinations against IRS records before submitting returns. It doesn’t catch every issue, but it flags the most common mismatches before they turn into corrections and withholding obligations.

Combined Federal/State Filing Program

The Combined Federal/State Filing (CF/SF) Program lets approved filers submit returns to the IRS and participating states in one FIRE transmission. The IRS forwards the data to states at no charge.⁹

The program covers Forms 1099-B, 1099-DIV, 1099-G, 1099-INT, 1099-K, 1099-MISC, 1099-NEC, 1099-OID, 1099-PATR, 1099-R, and 5498. Not all states participate, and the list changes. Each participating state has a two-digit code in Publication 1220 that must appear in the “B” record.

Joining the program requires submitting a test file coded for CF/SF to the FIRE test system. An approval letter follows an acceptable test. Testing is only required in your first year, but the IRS strongly recommends testing every year because record specifications can change. The IRS acts strictly as a forwarding agent, so confirming that each state received and accepted the data remains the filer’s responsibility.

1
Internal Revenue Service. Publication 1220 – Specifications for Electronic Filing of Forms 1097, 1098, 1099, 3921, 3922, 5498, and W-2G
2
Federal Register. Electronic-Filing Requirements for Specified Returns and Other Documents
3
IRS. General Instructions for Certain Information Returns (2026)
4
Internal Revenue Service. Filing Information Returns Electronically (FIRE)
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Internal Revenue Service. E-file Information Returns With IRIS
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Internal Revenue Service. IRIS Application for TCC
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Internal Revenue Service. About Information Returns (IR) Application for Transmitter Control Code (TCC) for Filing Information Returns Electronically (FIRE)
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Internal Revenue Service. Authorized IRS E-file Provider Locator Service for Tax Professionals
9
Internal Revenue Service. Combined Federal/State Filing (CF/SF) Program
10
IRS. IRS FIRE Logon
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IRS. Form 8809 – Application for Extension of Time To File Information Returns
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Internal Revenue Service. Application for a Waiver from Electronic Filing of Information Returns
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Internal Revenue Service. Information Return Penalties
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Internal Revenue Service. 20.1.7 Information Return Penalties
15
Office of the Law Revision Counsel. 26 USC 6721 – Failure to File Correct Information Returns
16
Internal Revenue Service. Backup Withholding