Introduction: The End of the FIRE System
For decades, the IRS Filing Information Returns Electronically (FIRE) system served as the primary electronic filing platform for information returns such as Forms 1099, W-2G, 1098, and other tax documents. That era is coming to an end. The IRS has developed the Information Returns Intake System (IRIS), a modernized, web-based platform that is replacing FIRE as the mandatory filing channel for information returns.
This transition is not optional. The IRS has been progressively migrating filers to IRIS, and for the 2025 tax year (filed in early 2026), IRIS is the primary system for electronic filing of information returns. Businesses that have relied on FIRE must adapt their workflows, software integrations, and document management practices to align with the new system or risk penalties for late or incorrect filing.
Mandatory E-Filing Threshold: 10 or More Returns
One of the most significant regulatory changes accompanying the IRIS rollout is the dramatically lowered e-filing threshold. Under previous rules, only businesses filing 250 or more information returns were required to file electronically. The IRS has reduced this threshold to just 10 returns, aggregated across all return types.
This means that if your business files a combination of, for example, seven 1099-NEC forms and four 1099-MISC forms, your total of 11 returns exceeds the threshold and you must file electronically through IRIS. The aggregation rule is critical because many small businesses that previously qualified for paper filing now fall under the electronic mandate.
Key details of the e-filing requirement include:
- Threshold: 10 or more information returns across all types combined
- Penalty for non-compliance: Up to $310 per return for failure to file electronically when required (2026 adjusted amount)
- Corrected returns: Original and corrected returns are counted separately toward the threshold
- Waiver available: Businesses can request a hardship waiver using Form 8508, but approval is not guaranteed
March 31, 2026 Deadline and Filing Requirements
For the 2025 tax year, the deadline for electronically filing most information returns through IRIS is March 31, 2026. This applies to forms including 1099-NEC, 1099-MISC, 1099-INT, 1099-DIV, 1099-B, 1099-R, 1099-S, 1099-K, and many others in the 1099 series, as well as 1098 forms and W-2G.
The IRIS platform offers two filing methods:
- IRIS Taxpayer Portal: A free, web-based tool where businesses can manually enter data for individual returns, designed primarily for small filers
- IRIS Application-to-Application (A2A): An API-based channel for bulk filing, designed for businesses filing large volumes or using third-party tax software
Businesses using the A2A channel must register for an IRIS Transmitter Control Code (TCC), which replaces the old FIRE TCC. This registration process can take several weeks, so organizations that have not yet applied should do so immediately to ensure they can file before the March 31 deadline.
Document Retention and Record-Keeping Obligations
Filing information returns through IRIS does not eliminate the need to retain supporting documentation. The IRS requires businesses to maintain records that substantiate the amounts reported on information returns for a minimum of 3 years from the filing date, though many tax advisors recommend retaining records for 7 years to cover the extended statute of limitations in cases of substantial underreporting.
Records that should be retained include:
- Copies of all filed returns: Including confirmation receipts from IRIS
- Supporting documentation: Contracts, invoices, payment records, and bank statements that substantiate reported amounts
- W-9 forms: Taxpayer Identification Number (TIN) certifications from payees
- Corrected returns: Both the original and corrected versions with documentation explaining the correction
- Communication records: Any correspondence with payees regarding TIN verification or backup withholding
The IRS has increased its use of automated matching programs that compare information returns against individual and business tax returns. Discrepancies trigger automated notices, and businesses must be able to produce supporting records quickly to resolve these inquiries without incurring additional penalties.
Preparing Your Organization for the Transition
The FIRE-to-IRIS transition requires both technical and procedural adjustments. Organizations should take the following steps to ensure a smooth transition:
- Verify IRIS access: Ensure your organization has an active IRIS account and, if filing in bulk, a valid Transmitter Control Code
- Update software integrations: If you use payroll or accounting software that previously connected to FIRE, confirm that the vendor has updated their integration to support the IRIS A2A channel
- Audit your return count: Calculate the total number of information returns across all types to determine whether you meet the 10-return e-filing threshold
- Implement a document management system: Organize all supporting records so they are easily retrievable in the event of an IRS inquiry
- Train staff: Ensure that personnel responsible for information return filing are familiar with the IRIS interface and new filing procedures
How Arhivix Helps
Arhivix simplifies the document retention requirements that accompany IRS information return filing. All documents are stored with AES-256 encryption, ensuring that sensitive taxpayer information, including TINs, payment amounts, and W-9 certifications, remains secure and protected from unauthorized access. Built on AWS S3 storage infrastructure, Arhivix provides the durability needed to meet the IRS retention period with confidence.
Every file upload, access, and modification in Arhivix is recorded in a detailed audit trail, giving your organization a clear, timestamped record of document handling. When the IRS sends an automated matching notice or requests documentation, you can retrieve the exact records you need in seconds rather than hours. Arhivix helps businesses stay organized, compliant, and ready for any inquiry that arises from their IRIS filings.
