TITLE: Preparing for the IRS FIRE System Retirement: Your Guide to IRIS and the Foreign Filer TCC Registration System
The IRS is retiring the FIRE system in 2026. From 1 January 2027, IRIS will become the sole electronic filing system for information returns, including current-year forms, prior-year forms and corrections.
This change matters if your UK, EU or other international business files US information returns. It is especially important if you issue Forms 1099 to US contractors or file Form 1042-S for US-source income paid to foreign persons.
The IRS has also introduced a Foreign Filer TCC Registration System. This gives eligible overseas filers a route to obtain the credentials needed to transmit returns electronically through the International Data Exchange System (IDES).
The key message: prepare before the FIRE deadlines
Do not wait until the 2027 filing season. Your filing system, user access and supporting data should be ready during 2026.
The important dates are:
| Date | What happens |
|---|---|
| 1 November 2026 | Last day to file test information returns through the FIRE Trading Partner Test System |
| 9 November 2026 | Last day to modify existing FIRE IR Applications for TCCs |
| 19 November 2026 at 3:00 p.m. ET | Final deadline to file information returns through FIRE |
| December 2026 | FIRE becomes read-only after its filing activity ends |
| 1 January 2027 | IRIS becomes the sole electronic intake system for information returns |
The IRS has also stopped accepting new FIRE applications for Transmitter Control Codes. Existing FIRE applications can only be updated until the relevant 2026 deadline.
You can review the current requirements on the IRS FIRE system retirement page.
Understand what IRIS replaces
The Information Returns Intake System, or IRIS, is the IRS platform replacing FIRE for electronic information return filing.
IRIS supports:
- Forms 1099 and other information returns.
- Form 1042-S.
- Current-year filings.
- Prior-year filings.
- Corrections.
- Automatic extension requests.
- Manual entry or CSV uploads through the taxpayer portal.
- Application-to-application filing through approved software.
From 1 January 2027, you cannot continue using FIRE for electronic submissions. A FIRE Transmitter Control Code is also not an IRIS credential. You must apply for a separate IRIS TCC if your authorised user has a US tax identification number.
The IRS states that electronic filing is mandatory when you have 10 or more information returns. This threshold applies from tax year 2023 and is generally calculated by aggregating covered information returns rather than counting each form type separately.
For example, you may reach the threshold by combining:
- Six Forms 1099-NEC for US contractors.
- Two Forms 1099-MISC.
- Two other applicable information returns.
That total may require electronic filing even if you have fewer than 10 forms of any single type.
Review the IRS IRIS electronic filing guidance before deciding which filing route applies to your business.
Check whether your business can use IRIS directly
IRIS requires authorised users to complete IRS identity verification. The normal process requires the user to hold a US taxpayer identification number, such as:
- A Social Security number (SSN).
- An Individual Taxpayer Identification Number (ITIN).
This created a practical barrier for many overseas businesses. A responsible officer or employee of a UK or EU company may have no SSN or ITIN, even when the business has a US EIN and reporting obligations.
If your authorised user has an SSN or ITIN, use the standard IRIS application process. Do not use the Foreign Filer TCC Registration System in that situation.
If your authorised users do not have an SSN or ITIN, the new foreign filer route may apply.
Use the Foreign Filer TCC Registration System if eligible
The IRS announced the Foreign Filer TCC Registration System in IRS Bulletin No. 2026-06, issued on 4 May 2026.
The system is designed for foreign filers whose authorised users lack an SSN or ITIN and therefore cannot obtain or maintain an IRIS TCC directly.
An approved foreign filer registration provides the credentials needed to transmit eligible information returns through IDES, including:
- Forms 1042-S.
- Applicable Forms 1099.
- Other information returns supported by the process.
The Foreign Filer TCC is separate from both FIRE and IRIS credentials. You cannot use a FIRE TCC or IRIS TCC to transmit returns through IDES.
Read the IRS Foreign Filer TCC Registration guidance and its official FAQs before registering.
Gather the information required for registration
Prepare your registration details before starting. The process requires several connected accounts and identifiers.
You will generally need:
-
An EIN for the foreign business.
The legal name entered during registration must match the legal name used when the EIN was issued. Matching the records correctly will reduce avoidable delays. -
A Login.gov or ID.me account.
This provides secure access to the Foreign Filer TCC Registration System. -
A responsible officer or authorised point of contact.
The responsible officer completes the registration and acts as the primary contact. -
A TCC GIIN.
The TCC Global Intermediary Identification Number supports the TCC request and IDES enrolment. -
A Foreign Filer TCC.
This is a system-specific five-character identifier used for IDES submissions. -
IDES enrolment.
You must enrol with the International Data Exchange System to transmit the relevant returns.
The responsible officer must also serve as the IDES account administrator. Keep the Foreign Filer ID and all registration credentials in a secure internal record. Losing access can disrupt your filing process at a critical deadline.
See how the change affects international ecommerce sellers
Example 1: A UK seller paying US contractors
Suppose your London-based ecommerce company uses US-based designers, customer support contractors or marketing specialists.
You should review:
- Whether each payee is a US person or foreign person.
- Whether you collected the correct Form W-9 or Form W-8 series documentation.
- Whether the payments require a Form 1099, such as Form 1099-NEC.
- Whether your total information returns reach the 10-return electronic filing threshold.
- Which authorised user will manage the IRS filing account.
If the authorised user has no SSN or ITIN, the Foreign Filer TCC route may be necessary. Do not assume that your UK company’s EIN alone gives you access to IRIS.
Example 2: A UK or EU business paying foreign persons from US-source income
Form 1042-S is used to re
