Electronic Filing Now Required for Filers of 10 or More 1099 Returns, Reduced from 250 

The IRS has replaced its FIRE system (File Information Returns Electronically) with the IRIS system (Information Returns Intake System). For details, see https://www.irs.gov/filing/e-file-information-returns-with-iris.The most significant change has to do with filing returns electronically. Previously, electronic reporting was required only when the number of 1099 returns equaled 250 or more. That threshold has now been lowered to filings of 10 or more, requiring electronic filing for most filers.

For tax year 2026, reportable in 2027, and subsequent years, the FIRE system is no longer available and all 1099-S filing with the IRS must be through the IRIS system. The FIRE TCC may not be used for filing under IRIS and you must obtain a new TCC for the IRIS system.

The process for filing electronically has also changed and requires several steps to establish an account with the IRS:

1. If no account has been previously created, create an account using ID.me.

2. Obtain a Transmitter Control Code (TCC). If you already have a TCC for the FIRE system, you must reapply for one prior to filing using IRIS.

To file up to 100 1099-S returns at a time, the CSV (Comma Separated Values) template that is available upon logging into the IRIS website must be used. For filings that involve thousands of returns, the IRS's A2A (Application to Application) method must be used.

Members who are responsible for completing the 1099-S reporting for their transactions should apply for their TCC as soon as possible to avoid any delays in filing.

The foregoing changes apply only to filing the 1099-S returns with the IRS; they do not affect the requirement of providing the sellers with their copy of the paper form 1099-S, which must be provided to them by February 15 of the year following the year of closing.

The deadline for filing 1099 returns with the IRS electronically is March 31 of the year following the year of closing.

For those transmitters/filers who must file their 1099-S returns with the IRS electronically, if you have applied for, but not received, your Transmitter Control Code or if you need additional time in which to file, obtain an extension by filing form 8809 Extension of Time to File Information Returns before the March 31 filing deadline.

If you experience any problems with filing under the IRIS system, contact the IRS Helpline, 866.937.4130

Questions? Contact Us.

[Updated: 08/20/2026]