The IRS is retiring the FIRE system on December 31, 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
Spring 2026
- Request written confirmation of your vendor’s IRIS TCC status
- Ask whether they are ready to file through IRIS for Tax Year 2026
Summer 2026
- Confirm whether your vendor requires any data changes on your end — specifically student name field formatting, address fields, and TIN completeness
Fall 2026
- Verify your vendor is ready to file Tax Year 2026 returns through IRIS
If you file directly
Spring 2026 — Start now
- Apply for an IRIS TCC immediately since IRS processing takes up to 45 days (IRIS TCC application)
- Identify all Responsible Officials and Authorized Delegates
- Ensure each person completes ID.me verification before the TCC application is submitted
Summer 2026 — Data and systems
- Audit student TIN records for completeness: domestic and international populations separately
- Audit student name fields in your SIS: IRIS requires separate first and last name fields
- Audit address fields for IRIS formatting compatibility
- Engage your ERP provider on IRIS compatibility
- Confirm any required system updates or data mapping changes
Fall 2026 — Testing and training
- Run a test data set through IRIS formatting requirements
- Surface and resolve any name, address, or TIN issues before January
- Train financial aid staff on the IRIS correction workflow
- Train registrar staff on the IRIS correction workflow
- Train student accounts staff on the IRIS correction workflow
How Tab Service Company handles the IRIS transition for 1098-T filers
Tab Service Company’s TAB1098-T platform (also knows 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.