TITLE: FIRE to IRIS Transition: Final Deadlines Every International Seller Must Know
The IRS is retiring the FIRE system in November 2026. If you file US information returns, you must prepare for the move to IRIS before the 2027 filing season.
This change matters to UK sellers in London, Manchester and Birmingham, EU ecommerce businesses, foreign-owned US LLCs and international companies selling into the US through Amazon FBA, Shopify and other marketplaces.
The IRS announced the transition in News Release IR-2026-99, published on 24 August 2026.
Act before these three FIRE deadlines
The transition includes three important dates. Missing the final date could prevent you from filing through FIRE.
1. Test your information returns by 1 November 2026
1 November 2026 is the final day to file test information returns through the FIRE Trading Partner Test System.
Use this deadline to:
- Test your filing software.
- Check your file format.
- Validate payer and recipient data.
- Identify rejected records.
- Confirm that your third-party filer can transmit successfully.
Testing early gives you time to correct technical errors before the production system closes. Do not wait until the final filing deadline to discover that your data file is invalid.
2. Update your FIRE application by 9 November 2026
9 November 2026 is the last day to make changes to Information Returns Applications for Transmitter Control Codes, commonly called TCCs.
Review your existing FIRE application now. Check:
- Responsible officials.
- Authorised contacts.
- Business details.
- Filing responsibilities.
- Third-party transmitter arrangements.
- The information returns your business expects to submit.
After this date, changes to your FIRE application will no longer be available in the same way. Keeping your records accurate helps prevent access and authorisation problems during the transition.
3. File through FIRE by 19 November 2026
19 November 2026 at 3 p.m. Eastern Time is the final deadline for filing information returns through FIRE.
That is 8 p.m. UK time on 19 November 2026.
This is the most important deadline for international sellers. If you have outstanding FIRE filings, corrections or other submissions, plan to complete them well before the final afternoon.
After the November maintenance window, FIRE will no longer accept information returns. From 1 January 2027, IRIS will be the sole IRS electronic filing system for information returns, including current-year, prior-year and correction filings.
Move from FIRE to IRIS before the 2027 filing season
IRIS, or the Information Returns Intake System, is the IRS replacement for FIRE. The IRS has provided two filing channels.
Use the free IRIS Taxpayer Portal for smaller filing volumes
The IRIS Taxpayer Portal is a free, web-based filing system.
You can use it to:
- Enter information manually.
- Upload data using a CSV file.
- File up to 100 returns per filing.
- Download payee copies.
- Maintain records of completed submissions.
The portal may suit a smaller business filing a limited number of 1099 forms. It is also useful if you do not have a compatible third-party filing system.
Prepare your data carefully. A CSV upload does not remove your responsibility to provide accurate taxpayer identification numbers, payment information and recipient details.
Use IRIS Application to Application for higher volumes
IRIS Application to Application, or A2A, is designed for high-volume filers using third-party software or their own systems.
This channel may be more suitable if you:
- File hundreds or thousands of information returns.
- Use accounting, payroll or compliance software.
- Need an automated system-to-system process.
- Already rely on a third-party transmitter.
- Want to reduce manual data entry.
Ask your software provider whether it supports IRIS A2A. Do this early because testing, authorisation and data mapping may take time.
Understand the IRIS TCC requirement
Your existing FIRE TCC will not automatically work with IRIS.
You must apply for an IRIS TCC through the IRS. FIRE TCCs and IRIS TCCs are system-specific. They are not interchangeable.
This is a key operational point for any business that currently uses FIRE for 1099 filing or other US information returns. Applying for the correct IRIS TCC early will reduce the risk of a last-minute filing failure.
Keep evidence of:
- Your IRIS application.
- TCC approval.
- User permissions.
- Software authorisation.
- Test submissions.
- Rejected and corrected records.
These records support a clear compliance trail if you need to investigate a filing issue later.
Check the foreign filer process
International sellers need to understand which IRS process applies to them.
A non-US filer without an SSN or ITIN may need to use the Foreign Filer TCC Registration system for the applicable electronic filing process. The registration process includes:
- Signing in through Login.gov or ID.me.
- Creating or accessing a Foreign Filer account.
- Obtaining a Foreign Filer ID.
- Obtaining a TCC GIIN.
- Enrolling in IDES where required.
- Allowing approximately three to six weeks for the process.
The Foreign Filer ID is not the same as a TCC. The TCC GIIN is also a specific identifier used for the relevant registration and enrolment process.
Do not assume that a Foreign Filer TCC, FIRE TCC, IRIS TCC and IDES credentials can be used interchangeably. They cannot. Confirm which channel applies to your filing obligation before submitting an application.
If your foreign business has an authorised user with a US SSN or ITIN, the IRS may direct you to apply for an IRIS TCC through the standard IRIS process instead. Review the latest IRS foreign filer guidance and IRIS TCC instructions before proceeding.
See how the change affects international sellers
Example 1: A UK Amazon seller filing US forms
A UK Limited Company based in London sells products to US customers through Amazon FBA. Its US reporting obligations may include 1099 forms or Form 1042-S, depending on the payments, recipients and structure involved.
The business should:
- Review which US information returns it files.
- Confirm whether it currently uses FIRE or a third-party transmitter.
- Test its files before 1 November.
- Review its FIRE application before 9 November.
- Submit any required FIRE returns before 19 November at 3 p.m. ET.
- Apply for the correct IRIS TCC or follow the applicable foreign filer process.
- Confirm that Amazon, its software provider or its filing agent has a 2027 IRIS workflow.
The same approach applies to sellers operating from Manchester, Birmingham or elsewhere in the UK.
Example 2: A foreign-owned US LLC using a third-party filer
A foreign-owned US LLC receives marketplace income and uses an external provider to prepare and transmit its information returns. The LLC may not interact with FIRE directly, but it remains responsible for the accuracy and timely submission of its filings.
The LLC should:
- Verify that its third-party filer is registered for IRIS and has a valid IRIS TCC.
- Ask whether the filer will use the IRIS Taxpayer Portal or A2A for the 2027 season.
- Obtain confirmation in writing that test files have been accepted in the IRIS environment.
- Review the filer’s timeline for completing the transition before November 2026.
- Check that the LLC’s own records—such as recipient name, address and taxpayer identification number—are up to date.
- Plan for a possible gap in filing capacity if the third-party filer is slow to migrate.
This example also applies to foreign-owned LLCs that do not have direct IRS filing accounts and rely entirely on external compliance partners.
Example 3: An EU business with Form 1042-S obligations
An EU ecommerce business with US-source payments may need to file Form 1042-S to report income paid to foreign persons. If it currently uses FIRE for this purpose, the transition to IRIS requires a fresh look at its entire filing setup.
The business should:
- Determine whether it files as a foreign filer or through a US-based agent.
- Secure the correct Foreign Filer TCC or IRIS TCC well ahead of the transition date.
- Complete any IDES enrolment if required for its specific filing type.
- Test its 1042-S data files in the new system before the end of the test window.
- Allow the three to six weeks processing time for foreign filer registration.
- Coordinate with any withholding agents to ensure beneficiary data matches.
Missing the transition deadlines could delay 1042-S filings and create compliance exposure for the business.
Prepare your transition plan now
The FIRE to IRIS transition is not a routine software update. It is a system-wide change that affects how information returns are tested, transmitted and tracked.
Build your plan around these steps:
Audit your current filing method
Identify every form your business files through FIRE. This may include Forms 1099-NEC, 1099-MISC, 1099-K, 1042-S or others. Verify whether you file directly or through a third party.
Confirm your TCC status
Check whether your existing TCC is a FIRE TCC or an IRIS TCC. If you have not applied for an IRIS TCC, start the process immediately. If you are a foreign filer, confirm whether the Foreign Filer TCC Registration system applies to you.
Contact your software provider
Ask your software vendor or filing agent whether they support IRIS A2A. Confirm their testing schedule and request evidence of successful IRIS test transmissions.
Set internal milestones
Work backwards from 19 November 2026. Set internal deadlines for completing test files, updating applications and finalising submissions. Do not rely on the IRS deadlines as your only reference points.
Document everything
Keep copies of all applications, approvals, test submissions, error reports and correction records. This documentation will be useful if the IRS contacts you about a filing issue during the transition period.
Act before the November 2026 cut-off
The FIRE system is closing. The IRS will not extend the 19 November 2026 deadline for individual filers or business filers, regardless of jurisdiction.
International sellers and foreign-owned entities face additional complexity because of the Foreign Filer TCC Registration process and the three to six week processing time. Starting the application process in mid-2026 gives you a realistic buffer.
If you file US information returns of any type, your next step is clear: test early, update your applications before 9 November, and complete all FIRE submissions before 19 November at 3 p.m. Eastern Time. Then move your entire workflow to IRIS before the 2027 filing season begins.
