From FIRE to IRIS: A Small-Office Transition Checklist for 2027

Small U.S. tax and accounting offices that use the Filing Information Returns Electronically (FIRE) system have a transition to plan. The IRS states that FIRE users must move to the Information Returns Intake System (IRIS) for tax-year-2026 information returns filed during the 2027 season.

This checklist covers office operations: access, ownership, software questions, testing dependencies, internal records, and follow-up. It does not determine whether an office or client must file a particular return, provide tax or legal advice, or guarantee access, compatibility, compliance, or a successful transmission.

Put the FIRE cutoff dates on the calendar

The IRS transition announcement lists three dates:

• November 1, 2026: FIRE testing cutoff.
• November 9, 2026: cutoff for IR Application/TCC changes.
• November 19, 2026, at 3 p.m. ET: FIRE filing cutoff.

Assign an internal owner to each date, record open dependencies, and choose a progress-review date. Those are office-management steps, not IRS requirements.

1. Find every FIRE touchpoint

Map where FIRE appears in the current workflow, including forms and client engagements, staff responsibilities, software providers, file preparation, review, testing, access administration, and escalation paths.

The goal is to identify transition work—not to decide whether a filing obligation exists. Direct questions about filing obligations or form coverage to the IRS or an appropriately qualified adviser.

2. Assign ownership of the IRIS TCC and access process

The IRS describes the IRIS Transmitter Control Code application as the request for authorization to participate in IRIS electronic filing.

Name a primary coordinator and a backup. In a non-sensitive internal record, track responsible roles, action dates, appropriate confirmation references, questions for the IRS or a software provider, and the next follow-up date.

Review eligibility and application details in the current IRS instructions. Keep passwords, credentials, taxpayer data, filed returns, and other sensitive records out of a general transition tracker.

3. Compare the Taxpayer Portal and A2A against the real workflow

IRIS offers two distinct intake paths. Office size alone does not determine which one fits.

According to the IRS page on filing information returns with IRIS:

• The IRIS Taxpayer Portal is free, supports manual or CSV entry, and accepts up to 100 returns at a time. This is a transaction capability, not a recommended annual volume.
• IRIS Application to Application (A2A) supports third-party or internally developed software and transmissions of up to 100 MB. The IRS identifies a TCC, API client ID, schema package, and successful Assurance Testing System (ATS) transmissions among the A2A dependencies.

Review how the office actually works. Does it use manual entry, CSV files, vendor software, or internally developed software? Which forms and tax years does it expect to handle? What does each provider currently support? If A2A is under consideration, who will own the technical setup and ATS work?

Confirm current requirements and form coverage with the IRS and relevant providers. The cited capabilities do not establish compatibility with a particular product or guarantee a transmission result.

4. Keep one dependency log

Record each unresolved question, the applicable IRIS path, responsible role, contact point, follow-up date, status, non-sensitive evidence location, and next review date.

Include API, schema, or ATS items only if A2A applies. This log is an internal management tool, not an IRS requirement or proof of readiness.

5. Preserve useful proof without collecting sensitive material

For each completed step, record what happened, when it happened, who handled it, and what remains open. Appropriate records may include dates, responsible roles, confirmation references, meeting notes, and vendor questions.

A completed checklist does not certify access, software compatibility, filing readiness, compliance, or successful transmission.

6. Monitor IRS updates

Assign someone to review the IRS transition and IRIS pages regularly. The transition announcement also points to channels such as QuickAlerts and working groups. Record each review date, any resulting office action, and unresolved questions.

Capabilities and form coverage may depend on the processing year or tax year. Check current IRS information before relying on an older internal note.

Copyable office checklist

• Add the three FIRE cutoff dates to the office calendar.
• Assign a primary owner and backup for each workstream.
• Map every current FIRE touchpoint.
• Assign ownership of the IRIS TCC and access process.
• Compare the Taxpayer Portal and A2A with the actual workflow.
• Confirm relevant form coverage and software support.
• Record applicable access, testing, software, and vendor dependencies.
• Preserve non-sensitive confirmation references.
• Keep credentials, taxpayer data, and filed returns out of the tracker.
• Give each unresolved item a next action and review date.
• Schedule recurring reviews of IRS updates.

Organize client follow-up work

Once the office has identified its follow-up tasks, build a client follow-up checklist with Intaxion. Use it as a complementary bilingual tool for organizing follow-up work. Intaxion is not presented here as a system for filing, transmitting, storing, or validating information returns or taxpayer data.

IRS sources

• IRS reminder: Information Return e-file System transitioning to a new platform
• E-file information returns with IRIS
• IRIS application for TCC

Sources

• https://www.irs.gov/pub/irs-pdf/p5717.pdf