IRS FIRE system ends November 19: 8 steps for 1099 filers

The IRS said it plainly in a news release this August (IR-2026-99, Aug. 24, 2026): the FIRE system stops accepting information returns on November 19, 2026, at 3 p.m. Eastern, and every tax year 2026 return that used to go through it will have to be filed through IRIS in the 2027 filing season. For most Oklahoma businesses, the IRS FIRE system was the plumbing behind their 1099s, whether they knew it or not. Their payroll provider or CPA used it, the returns went out, and nobody thought about the transmitter code sitting in a drawer.

That plumbing is being pulled out. The question we'd put to any business since the release came out: who, exactly, is going to file your 1099s in January, and do they have an IRIS credential yet? In our experience the answer is often a shrug. Here are the steps, in the order we'd work them.

Step 1: Confirm whether you're required to e-file at all

Before worrying about the IRS FIRE system or its replacement, settle the threshold. IRS Tax Topic 801 states the rule: a person must file information returns electronically if they're required to file at least 10 returns in a calendar year. Fewer than 10, and paper is still permitted (electronic filing is still allowed too).

The wrinkle is how the 10 are counted. Tax Topic 801 describes the count as an aggregate of almost all information return types covered by the regulation, which is 26 CFR 301.6011-2. That means W-2s and 1099s are added together. An Oklahoma contractor with six employees and four subcontractors is at 10 and must e-file, even though no single form type reaches the threshold on its own.

Two more pieces from the same topic matter here. Employers whose combined total of 10 or more includes Forms W-2 file those W-2s electronically with the Social Security Administration, not through IRIS. And the Affordable Care Act forms (1094-B, 1095-B, 1094-C, 1095-C) go through a separate system called AIR. IRIS is the home for the 1099 family and the other forms FIRE used to carry.

Who gets a 1099 in the first place, and at what dollar amount, is a different question. The reporting threshold changed under 2025 federal legislation, and we covered it separately in our piece on the new 1099 threshold for Oklahoma payers. This article assumes you already know which payees need a form.

Step 2: Find out whose IRS FIRE system code you've been using

Every electronic filer, or the service that files for them, works under a Transmitter Control Code (TCC). It's the IRS's credential for the filing entity. If a CPA firm or payroll vendor has been filing your 1099s, the TCC belongs to them, and the question is whether they've obtained an IRIS one. If you filed in-house through FIRE, the TCC is yours, and the news is worse.

IRS working-group materials on IRIS are blunt about this: TCCs are not interchangeable between intake systems. A FIRE TCC works only in FIRE. An AIR TCC works only in AIR. An IRIS TCC works only in IRIS. There's no conversion, no grandfathering. The code you've used for years becomes a dead credential when FIRE closes.

This is the point most small businesses miss. They assume the IRS will migrate them. It won't. Someone has to apply.

Step 3: Apply for the IRIS TCC now, not in January

The IRIS Application for TCC is the first step the IRS lists in its own release, and the processing time is the reason we put it third rather than last. The working-group materials say to allow up to 45 calendar days for application processing. Count backward from January 31, when Oklahoma's 1099-NEC file is due to the OTC, and the math gets tight fast. An application started in mid-December may not have a code in hand before the first filing deadline.

Application mechanics, as described in those materials:

• A Responsible Official (RO) must initiate the application, and the filer needs an EIN.
• Every RO, authorized delegate, and contact must be verified through ID.me, the IRS's identity verification provider.
• The application asks you to choose a role: Issuer (filing your own returns), Transmitter (filing for others), or Software Developer.
• Each RO signs the submission page with a 5-digit PIN.
• At least two ROs are required, except for sole proprietors, single-member LLCs, and single-member S corporations.
• Once the status reads Completed and suitability shows Passed, the TCC is assigned and the IRS mails Letter 6524C, the acceptance letter. The code also appears on the application summary page.
• An application left in Saved status for more than 90 days is deleted.

The two-RO rule trips up closely held companies more than anything else on that list. A multi-member LLC or a corporation with one active owner has to name a second responsible official, and that second person has to complete ID.me verification personally. If your bookkeeper is the only one who touches tax filings, this is the moment to decide who the second name will be, because the application can't be finished without them.

One more item from the application matters for Oklahoma filers specifically. The Combined Federal/State Filing (CF/SF) program, which lets the IRS forward certain 1099 data to participating states, is elected on the Firm Information page of the IRIS TCC application. We come back to why that matters in Step 6.

Step 4: Decide between the Taxpayer Portal and A2A

IRIS has two doors. The IRS release describes the Taxpayer Portal as a free, web-based filing system that handles up to 100 returns at a time. You can key forms in manually or upload a CSV file, and the portal lets you download payee copies and keep records of what you filed. The second door, IRIS Application to Application (A2A), is for filers using third-party or self-developed software who need to move larger volumes.

For most of the businesses we work with, the portal is enough. But its limits deserve a look before you commit. The working-group materials describe:

• Up to 100 forms per submission and 100 records per CSV file.
• One form type and one tax year per CSV upload. A file mixing 1099-NEC and 1099-MISC won't go.
• Issuer management that stores up to 25 saved issuers, which matters for a CPA firm or a holding company filing for several entities.
• Automatic 30-day extension requests, available only until the return's due date.
• Recipient copies that download as a zip file containing a separate PDF for each record plus a recipient checklist.

A business with 300 payees can still use the portal; it just means three or more separate uploads per form type. Whether that's acceptable depends on who's doing the work and how much they bill by the hour. Past a certain volume, software that talks to A2A pays for itself, and the Software Developer role on the TCC application exists for exactly that path.

Step 5: Rebuild the filing calendar around the two systems

The dates in IR-2026-99 that matter for the shutdown:

• November 1, 2026: last day to file test returns through the FIRE Trading Partner Test System.
• November 9, 2026: last day to make changes to Information Returns Applications for TCC.
• November 19, 2026, at 3 p.m. ET: last day to file information returns through FIRE.

After that, per the release, FIRE no longer accepts submissions, and tax year 2026 returns are filed through IRIS during the 2027 filing season. The November 1 date has already passed as we write this. The November 19 date is still open, which means one specific thing: if you have late or corrected prior-year returns that you've been meaning to send through FIRE, the window to do that with the old credential is about two weeks wide.

A practical consequence we'd flag for anyone with a messy prior year. Once FIRE stops accepting submissions, the release leaves IRIS as the only intake system for the forms FIRE carried, which as we read it means a later correction to a return originally filed through FIRE will need an IRIS TCC. If you don't have one, the correction waits on the 45-day application clock. Prior-year cleanup is a reason to get the application in even if a vendor will handle your current-year filing.

Step 6: Handle the Oklahoma side separately through OkTAP

Here's where the federal transition meets state practice, and where we see the most confusion. The Oklahoma Tax Commission's tax document filing page states that the OTC no longer accepts paper 1099s, Forms 501, 500-B, W-2s, or W-3s. Everything goes through the business's OkTAP account: log in, open the More tab, and use the W-2/1099/500 Filing Center.

The CF/SF election you made on the IRIS application does part of the Oklahoma work, but not all of it. The OTC page says CF/SF covers 1099s with one exception: the 1099-NEC. That form is excluded from CF/SF and must be submitted directly to the OTC. Forms 500-B and the 501 summary are also outside CF/SF and go through OkTAP. So a business that pays contractors and elects CF/SF still has an OkTAP upload to make every January, because the 1099-NEC is the one the state wants to receive directly.

Two format points from the OTC page. First, the OkTAP upload asks for a transmitter control code, and the OTC's own answer is to leave it blank; the code is used only by CF/SF, not by OkTAP. Second, the file must match the IRS Publication 1220 layout, and the page warns (in its W-2 instructions) that converted files will not attach. A spreadsheet export won't work for the 1099 file either. It has to be the fixed-width specification file, which is normally what a payroll or 1099 software package produces.

Oklahoma due dates

The OTC page lists:

• 1099-NEC: January 31, filed directly with the OTC.
• 1099-R, 1099-INT, 1099-DIV, 1099-OID, 1099-B, 1099-G, and 1099-MISC: March 31.
• W-2 and W-3: January 31, with no extension available.
• Forms 500-B and 501: the pass-through entity's income tax return due date, including extensions.

For the 1099 and 500-B filings, a due date falling on a weekend or legal holiday rolls to the next business day. On penalties, the OTC page is specific only about W-2/W-3: it may impose a penalty of up to $1,000 if those aren't filed within 30 days of the deadline. The page states no figure for late 1099s, and we won't invent one. The federal information return penalties are their own regime, which we'll leave for another day.

Step 7: Change how you prove you filed

On the OTC side, the help page says you'll receive a confirmation number when you upload a file, the OTC will not notify you when the file is processed, and it emails only if there's a problem. It also says you will not be able to obtain copies of submitted 1099, 500-B, or W-3 information from the OTC. The only record is the one you keep.

Federal records are a little easier. The IRIS Taxpayer Portal lets you download payee copies and keep records of filed forms, which is better than nothing, but the discipline is the same. Our habit is to treat the confirmation screen like a certified mail receipt: capture it and file it with the return data. When a payee disputes a form two years later, or a notice arrives questioning whether a return was filed, that screenshot settles the question in a sentence. Without it, you're reconstructing from memory against an agency record.

This connects to a problem we've written about before. Mismatched or missing payee information surfaces as a CP2100 notice, and the payer's obligations after that notice depend on being able to show what was filed and when. Filing records are the foundation of the response.

Step 8: Learn the correction rules before you need them

The last step is one nobody takes until it's urgent. The IRS working-group materials say the IRS cannot delete a filed return for the transmitter or issuer. There's no undo button. If you submit a duplicate, or file a 1099 for someone who shouldn't have received one, the fix is to file a correction that sets all the money amounts to zero. Corrections are permitted only for transmissions showing Accepted or Accepted with Errors status.

Think about what that means in practice. A zeroed correction is a second return in the IRS's system and in the payee's file. It's also a second return in yours, and it has to be explained if an examiner ever lines up your 1099 filings against your general ledger. That cleanup tends to become a line item in an audit response, not because anything was wrong, but because the paper trail needs narration.

Which brings us to the honest counter-consideration. IRIS is, by the IRS's description, free and requires no special software. For a business filing a dozen 1099s, the shift from FIRE is a modest inconvenience and the portal will serve. The 45-day TCC clock and the two-RO rule are the real friction, and both are solved by starting in November instead of January. The government's interest in this transition is legitimate too: a single intake system with identity-verified responsible officials is harder to abuse than the one it replaces.

Where this gets bigger than a filing chore

The transition itself isn't a legal problem. The exposure is what it reveals. A business that can't answer "who files our 1099s and under whose credential" usually also can't answer whether backup withholding was ever required or whether the state got its 1099-NEC file directly. Those are the questions that turn a routine information return into a controversy, and the FIRE shutdown is simply forcing the inventory a few months earlier than usual.

If the inventory turns up a gap, that's generally the moment a conversation with counsel earns its keep. You can reach us through the contact page or our Oklahoma City office. Sorting out a filing structure in November is almost always cheaper than explaining one in a notice response next summer.

This article is general information about Oklahoma, Texas, and federal law, not legal advice, and it does not create an attorney-client relationship. Facts matter; talk to a lawyer about yours.