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The IRS is retiring the FIRE system on November 19, 2026. Beginning with Tax Year 2026, all 1098-T returns must be filed through IRIS. What that requires depends entirely on whether a vendor manages your 1098-T filing or you file directly.
What changes under IRIS and who it affects
If you use a vendor
Your vendor handles the transition. You don’t need to apply for a TCC, complete testing, or change how corrections are filed. Your only responsibility is making sure the student data you send them meets IRIS formatting requirements, specifically the two issues below.
Student name and address formatting
IRIS requires first and last name fields to be submitted separately while FIRE accepted combined name fields. Address fields have similarly been separated into individual fields in the current IRS instructions: instead of one large field for the whole address, there will be separate fields for address line 1, line 2, and so on.
Student TIN completeness
IRIS validates Taxpayer Identification Numbers at submission and flags mismatches immediately while FIRE returned errors weeks or months later via CP2100 notice. Missing or incorrect student TINs are your institution’s responsibility to resolve before your vendor can file. The IRS permits filing without a student TIN only if a written solicitation was made by December 31 of the filing year.
If you file directly
Everything above applies, plus the following.
Get a new TCC
IRIS requires a new IRIS-specific Transmitter Control Code (TCC) and existing FIRE TCCs cannot be used. You must apply for one before you can file anything. The IRS states the application “may take up to 45 days for processing”. (IRS — E-file information returns)
ID.me identity verification
Every person listed on the TCC application including Responsible Officials and Authorized Delegates must individually verify their identity through ID.me before the application can be submitted.
Learn to Use the IRIS Taxpayer Portal
The IRIS Taxpayer Portal accepts CSV files or manual form entry, but it only accepts up to 100 forms per submission (IRS — E-file information returns with IRIS; IRS Publication 5717, Rev. 2-2026).
Correction process. Under IRIS, corrections are made record-by-record within the portal. FIRE, on the other hand, required re-uploading a full replacement file. Staff responsible for corrections must be trained on the new workflow before the January filing window opens.
Action checklist
If a vendor manages your filing
October
- Get written confirmation that your vendor files through IRIS under its own TCC and is ready for Tax Year 2026 1098-Ts.
- Ask what data changes they need from you, specifically separate first and last name fields, separate address fields, and complete student TINs.
November–December
- Run a test file through your vendor and resolve any name, address, or TIN issues it flags.
- Confirm who on your team reviews and approves the file before transmission.
January
- Send final data early enough to meet the February 1, 2027 deadline for student copies.
- Confirm your vendor handles corrections through IRIS and that your staff knows how to request one.
If you file directly
October
- If you don’t have an IRIS TCC yet, apply now. Processing can take up to 45 business days, which pushes approval into December. If that’s too late, see your options for filing without an IRIS TCC.
- Make sure every Responsible Official and Authorized Delegate has completed ID.me verification.
- Audit student records: TINs for domestic and international students, separate first and last name fields in your SIS, and address fields in the new format.
November–December
- Confirm with your ERP or SIS provider that it can produce IRIS-compatible data.
- Run a test data set and fix any name, address, or TIN issues before year-end close.
- If you have Tax Year 2025 corrections to file through FIRE, submit them before FIRE closes on November 19. After that, corrections go through IRIS.
January
- Train financial aid, registrar, and student accounts staff on the IRIS Taxpayer Portal correction workflow.
- File and furnish student copies by February 1, 2027. Remember that the Portal accepts up to 100 forms per submission, so plan batches for larger volumes.
How Tab Service Company handles the IRIS transition for 1098-T filers
Tab Service Company’s TAB1098-T platform (also known as TSC1098-T or TS1098-T) manages the complete 1098-T filing lifecycle: student data validation, TIN verification, IRS e-filing through IRIS, printing/mailing and electronic delivery to students. Institutions using TAB1098-T do not need to apply for their own IRIS TCC or manage data formatting. Tab Service holds the IRIS Transmitter TCC and files on behalf of client institutions.
Higher education clients that also file Form 1099 for contractors and vendors, or Form 1095 for ACA compliance, can consolidate all three form types under a single TAB1099/TAB1098-T engagement. This reduces the number of separate vendor IRIS integrations the institution needs to manage.
