This post is for filers who have no IRIS TCC, a pending application, or a TCC but no way to transmit their volume. It covers the timeline from early October and the options for filing tax year 2026 returns on time.
New to the transition? Our FIRE to IRIS transition guide covers the background.
Timeline
An IRIS TCC application can take up to 45 days to process. IRS publications differ on what that means. Publications 5717 and 5718 say 45 calendar days; Publication 1099 says a typical application is processed within 45 business days. Counting from October 7, that’s about November 21 on the calendar-day reading and about December 14 on the business-day reading (skipping weekends and federal holidays). The later date is the safer planning assumption. Other dates in that period:
| Date | What happens |
|---|---|
| Early October 2026 | A TCC application submitted now can take up to 45 days: about November 21 on the calendar-day reading, about December 14 on the business-day reading |
| November 2026 | IRIS A2A Assurance Testing System (ATS) testing generally opens for the new tax year |
| November 19, 2026, 3 p.m. ET | Last day to file anything through FIRE, including corrections |
| Early December 2026 | IRIS typically pauses for its annual changeover (confirm the date on the IRS’s IRIS status page) |
| January 2027 | IRIS opens for the 2027 filing season (it opened January 6 in 2026; check the IRS for the 2027 date) |
| February 1, 2027 | Form 1099-NEC due to the IRS and to recipients (January 31 falls on a Sunday) |
| March 31, 2027 | Electronic filing deadline for most other 1099s |
For the full list by form, see 2027 Tax Form Deadlines.
The timeline is tightest for filers building their own A2A connection. A TCC that arrives in mid-December leaves a few weeks, overlapping year-end close and the holidays, to finish development, pass ATS testing, and go live before Form 1099-NEC is due. Form 1099-NEC also has no automatic filing extension.
Filer situations
Your options depend on how far along you are.
You haven’t applied for an IRIS TCC. Your FIRE TCC won’t carry over, and the IRS stopped accepting new FIRE TCC applications on July 21, 2026. Filing directly through IRIS this season depends on an approval that may not come until December.
Your application is pending. Approval timing is set by the IRS. Also check which TCC you applied for: the Taxpayer Portal and A2A each require their own IRIS TCC. A Portal TCC won’t let you transmit through A2A.
You have an IRIS TCC but can’t transmit at your volume. A TCC is only the first step for A2A. You also need an API Client ID, the IRS schema package, software that generates valid IRIS XML, and completed IRS testing in ATS (a one-time communication test at minimum, and full scenario testing if you write the software yourself). If your system still exports Publication 1220 FIRE files, that file won’t work in IRIS as-is.
Your options for this filing season
1. File under a provider’s TCC
An IRS-authorized provider that transmits through IRIS A2A under its own TCC can file your returns without any IRIS credentials on your side. No TCC application, no API Client ID, no ATS testing. For most organizations without a TCC today, this is the only option that doesn’t depend on IRS approval timing. Look for a provider that already has a working IRIS A2A connection and can accept the file format your system produces now.
2. Use the IRIS Taxpayer Portal, if your TCC arrives in time
The Portal is free and needs no development, but it still requires an IRIS TCC for the Portal. It’s built for smaller volumes: you key in forms or upload CSV files (a CSV can hold up to 250 records, but each submission is limited to 100 forms), and corrections are made by hand. It can work for an organization with a few dozen forms and a TCC approved in December. It is less practical for thousands of records with a February deadline.
3. Paper, only if you qualify
Paper isn’t a general fallback. Businesses filing 10 or more information returns in a calendar year (counting all types together, including W-2s) must file electronically. A waiver from e-filing requires Form 8508, showing undue hardship, filed on paper (it can’t be filed electronically) at least 45 days before the returns are due. For returns due February 1, 2027, that means by about December 18, 2026. Filers who are required to e-file but don’t, without an approved waiver, can face a penalty on the returns above the tenth, unless they show reasonable cause.
4. Extensions
Form 8809 gives an automatic 30-day extension to file most information returns, but not Form 1099-NEC or W-2. Extensions for those aren’t automatic and are granted only for the specific hardship reasons listed on the form, and must be requested on a paper Form 8809. Form 8809 also doesn’t extend the deadline to furnish recipient copies; that takes a separate request on Form 15397.
Continue the TCC application
Completing an IRIS TCC application is still useful when a provider files this season:
- It’s a backup. If you ever need to file a handful of forms yourself, a Portal TCC lets you do it.
- It’s ready for next year. If you later decide to build your own A2A connection, you won’t be starting the clock in the fall again.
- It stays active. An IRIS TCC remains valid as long as it’s used at least once every three consecutive years.
Apply through IRS e-Services using the IRIS Application for TCC. Each authorized user needs to verify their identity, so line up the right people early. Publication 5903 walks through the application step by step.
How TAB1099 lets you file without your own TCC
TAB1099 IRIS e-filing transmits your returns through IRIS A2A under Tab’s own TCC. Our connection is already built and operating, so your filing doesn’t wait on an IRS approval.
- No IRIS credentials on your side. No TCC, no API Client ID, no ATS testing.
- Keep the file you have. Upload Publication 1220 FIRE files as they are today, or send IRIS XML, Excel, CSV, or JSON. We convert to IRIS XML and validate every record against IRS business rules.
- Send it your way. Upload directly or connect by API or SFTP.
- Review before it’s sent. With Self-Serve, nothing goes to the IRS until you’ve reviewed it.
- Corrections included. Pre- and post-filing corrections are filed through IRIS with no per-correction fees.
Choose Self-Serve if you want IRIS transmission while keeping your own workflows. Choose Full Service to hand off the whole process. It adds data analyst review, printing and mailing on IRS-approved paper, and electronic recipient delivery.
Tab has been an IRS-authorized e-file provider since 2005, is SOC 2 compliant, and runs a fully operational IRIS A2A connection unaffected by the FIRE retirement.
TAB1099 IRIS e-filing
If your IRIS TCC won’t be ready in time, or your systems can’t produce IRIS XML yet, TAB1099 can file your 1099s through IRIS this season using the files you already have.
Learn more about TAB1099 IRIS e-filing and FIRE to IRIS transition support. To get started, contact us or call 312-527-4306.