IRS Form 1099 Reporting Is Changing: Preparing Higher Education Institutions for the Shift from FIRE to IRIS

August 20, 2026

By: Frank C. Mayer and Lyndon E. Hall

The method for filing Forms 1098, 1099 and other information returns with the Internal Revenue Service (IRS) has gone through a major shift. As we reported in 2025, the IRS has launched its new Information Return Intake System (IRIS), which went live in November of 2025 and will completely replace the Filing Information Returns Electronically (FIRE) platform starting in 2027. This shift affected how all taxpayers, including colleges and universities of all sizes (higher education institutions), file forms like 1098-T, 1099-MISC, 1099-NEC, 1099-K and 1098, among others. The shift in systems is not optional – and failing to prepare could result in missed deadlines, rejected filings or compliance issues.

Below are some common questions and answers related to this shift.

Who is impacted? 

This change will apply to any taxpayer, including higher education institutions, responsible for filing information returns with the IRS, including but not limited to Forms 1098-T, 1042-S 1099-MISC, 1099-NEC, 1099-DIV, 1099-INT, 1099-K, 1098 and other similar filings within the 1098 and 1099 series. For higher education institutions, this transition will affect more than the accounting department or bursars office, and likely will require extensive coordination throughout various departments and third-party vendors that handle payroll, compliance or other interconnected reporting areas. 

What is changing?

The IRS replaced its older electronic filing system, FIRE, with a new web-based system, IRIS, intending to simplify and modernize the information return filing process. IRIS is mandatory beginning with tax year 2026 filings which are due in 2027. In addition, as part of the IRS’ paperless processing initiative, paper filings will no longer be permitted, meaning that all information returns will need to be filed within IRIS starting on Jan. 1, 2027. 

Higher education institutions will have two filing options, depending on the number of information returns to be filed within IRIS: 

  1. Taxpayer Portal – Easy Online Filing. This option may be used for higher education institutions filing less than 250  information returns. Higher education institutions can manually enter data or upload a spreadsheet, and no special software is needed.
  2. Application-to-Application (A2A) – Bulk Filing. This option is designed for higher education institutions filing 250 or more information returns. Higher education institutions can send data directly from their software to the IRS using an XML format. This option requires setup and testing, so early preparation is key, including connecting with third-party vendors to confirm they are able to file or help process returns within IRIS. 

When is this change effective? 

  • IRIS Launch: Nov. 2025
  • FIRE System Retirement: Dec. 31, 2026
  • Last Tax Year for FIRE: 2025 (filed no later than Dec. 31, 2026)
  • First Tax Year for Mandatory IRIS: 2026 (filed in 2027)  
     

Where will higher education institutions be able to access IRIS? 

Higher education institutions can access IRIS through the IRS online platform. However, depending on filing volume, higher education institutions can utilize assistance from a third-party provider to ensure a smooth transition. All users that will be filing on behalf of a higher education institution, including “Responsible Parties” and “Authorized Delegates,” must authenticate through their own individual ID.me accounts to then be able to access a higher education institution's IRIS account.

Why is the IRS changing the system? 

According to the IRS, IRIS is intended to improve efficiency and accuracy: it allows for real-time data validation and corrections, stores filed forms, allows higher education institutions to download and print recipient copies, request extensions and file certain corrected returns – and is a more modern, user-friendly system.

How can higher education institutions prepare to use IRIS? 

The transition to IRIS involves several steps and getting ahead of the process will help avoid delays or filing issues. We recommend taking the following steps as early as possible: 

  1. Determine filing volume. Higher education institutions with less than 250 information returns can use the Taxpayer Portal to file; however, higher education institutions with 250 or more information returns will need to use the A2A modality for bulk filing.
  2. Prepare for XML Filing. If expecting to use the A2A modality, begin data mapping and software integration. As XML is a specialized format, higher education institutions should obtain assistance from a developer or their current tax or payroll service provider.
  3. Register with the IRS. Higher education institutions will need an EIN and an ID.me account specific to the Institution.  As part of the registration process, each Institution must also designate at least two “Responsible Parties” and may assign up to two “Authorized Delegates” who are able to manage filings. These can include third parties or service providers who are authorized to file the Information Returns. 
  4. Apply for a New Transmitter Control Code (TCC). A new TTC that is specific to IRIS will be required, as legacy TCC codes from FIRE cannot be used. Higher education institutions may need more than one TCC depending on role and filing method. During registration, higher education institutions and individuals filing on behalf of the Institution must select a role that reflects how they will interact with the system: an “Issuer” files forms for their own Institution using the same EIN registered with IRIS; a “Transmitter” files on behalf of other businesses or themselves using an SSN – only one role is needed if performing both functions; and a “Software Developer” builds or manages software that connects to the IRIS system but does not submit forms directly. The TCC application and approval process can take up to 45 days to complete.
     

If you have any questions or concerns related to the foregoing, please contact Frank C. Mayer, chair of Bond’s tax law practice, E. Katherine Hajjar, co-deputy chair of Bond’s higher education practice, Lyndon E. Hall or the Bond attorney with whom you are regularly in contact.