The short answer: if you file 1099s yourself, your old system is about to stop working
The IRS is retiring FIRE, the Filing Information Returns Electronically system that businesses have used for decades to submit 1099s. The last day to file through FIRE is November 19, 2026, at 3 p.m. Eastern Time. From January 1, 2027, the Information Returns Intake System — IRIS — is the only way to e-file 1099s, including current-year returns, prior-year returns, and corrections.
That sentence matters a lot more if you hire other freelancers than if you only work for clients. Here is the distinction that trips people up, stated plainly: if clients pay you, you receive 1099s and you do not file them. If you pay subcontractors, virtual assistants, editors, designers, or other non-employees for your business, you are the filer, and this change lands squarely on your desk.
And there is a timing trap. An IRIS Transmitter Control Code (TCC) — the five-digit code that identifies your business for e-filing — is not the same as your old FIRE TCC. Your FIRE code does not carry over. The IRS says a typical TCC application can take up to 45 business days to process. Count backward from the January filing season and you can see why November is the month to act, not January.
This is not tax advice, and it is not a substitute for a CPA. Tax rules depend on your entity type, your state, and your exact payment history. What follows is a practical, verified walkthrough of the deadlines, the two IRIS channels, and a week-by-week plan so a small freelance business does not get caught in January with forms due and no way to file them.
First, figure out whether you are a filer at all
I have watched freelancers panic about this story for the wrong reason, so let us sort this out before anything else.
You are probably NOT a filer if:
- You work solo, clients pay you, and you never pay anyone else for business services.
- The only people you pay are employees on a W-2 (those go through the Social Security Administration, not IRIS).
- You pay for software, hosting, or subscriptions — those are vendor purchases, not payments for services by a non-employee that trigger a 1099-NEC in the usual sense, though edge cases exist and a CPA can confirm yours.
In that case, read the deadline section once, file it away, and move on. Nothing about FIRE retiring changes what your clients send you.
You probably ARE a filer if:
- You hired a subcontractor, editor, designer, developer, bookkeeper, or virtual assistant in 2026 and paid them for services as part of your trade or business.
- You run a small agency, a content business, or a production setup where other freelancers do client work under your name.
- You paid an attorney or another provider of legal services — those payments have their own reporting quirks even when the payee is incorporated.
If that sounds like you, keep reading. The rest of this article is written for you.
The three dates that actually matter
The FIRE retirement is not a single switch being flipped on one day. The IRS published a staged wind-down in its September 2026 QuickAlerts notice, and three dates do the real work (see the FIRE to IRIS transition guide and this IRS FIRE retirement summary for small businesses):
November 1, 2026 — already passed. This was the last day to file test information returns through the FIRE Trading Partner Test System. If you test transmission formats, that window is closed. It does not affect a normal filer who submits real returns, but it is a useful signal: the IRS has been closing doors in stages, not all at once.
November 9, 2026 — five days from now. This was the last day to make changes to an existing FIRE application for a Transmitter Control Code. After that point, existing FIRE applications go read-only. In plain terms, you cannot tidy up your old FIRE setup anymore. You can only move forward into IRIS.
November 19, 2026, at 3 p.m. ET — the hard cutoff. This is the last day to submit information returns through FIRE itself. After the November maintenance window, FIRE stops accepting submissions entirely.
January 1, 2027 — the new normal. From this date, IRIS is the only electronic channel for information returns: current-year returns, prior-year returns, and corrections alike. There is no grace period in which FIRE quietly keeps working for stragglers.
Put those together and the practical deadline is not January. It is now. A TCC application that takes up to 45 business days, started in mid-November, can easily run into January. Started in December, it can run past the date your 1099-NEC forms are due.
The other 2026 change that changes your filing list: the $2,000 threshold
The FIRE-to-IRIS switch is not the only 2026 change, and the two changes interact. For payments made in 2026, the reporting threshold for Form 1099-NEC rose from $600 to $2,000, under the One Big Beautiful Bill Act (P.L. 119-21, section 70433). That means, for 2026 payments, you generally issue a 1099-NEC only when you paid a single non-employee $2,000 or more across the whole calendar year.
That is a per-payee, per-year test, not a per-invoice test. Four invoices of $600 to the same editor add up to $2,400, and that crosses the line. One $1,900 payment to a designer does not, on its own, trigger a form — though the income is still taxable to the recipient whether or not a form is issued, and that point is worth repeating to anyone who thinks “no form means no tax.”
Our earlier breakdown of the new threshold walks through the per-payee math in detail: 1099-NEC threshold 2026: $2,000, not $600. If you have not yet rebuilt your 2026 payee list under the new threshold, do that before you touch IRIS. There is no point applying for a filing system for people you no longer need to report.
The December 2026 revision of Form 1099-NEC also adds new boxes — box 1b for cash tips included in box 1a, box 1c for the Treasury Tipped Occupation Code, and box 1d for qualified overtime compensation. Most freelancers hiring other freelancers will not use those boxes. If you pay tipped workers, flag it for your CPA rather than guessing.
The deadlines for the forms themselves
For payments made in 2026 and filed in early 2027, the headline deadline is:
- Form 1099-NEC: due to recipients and to the IRS by February 1, 2027. January 31, 2027 falls on a Sunday, so the deadline shifts to Monday, February 1. Do not plan around January 31 and then discover your system needs a business day you do not have.
Other 1099 forms have their own recipient and IRS dates, and some differ between paper and electronic filing. The NEC is the one most freelancers deal with, and it is also the least forgiving: recipient and IRS copies share the same date, so there is no “send it to the contractor now, file with the IRS later” slack.
Late or missing forms carry penalties quoted for 2026 at $60 to $340 per form, with the exact amount depending on how late the form is and the size of the filer. The IRS adjusts those amounts for inflation. A ten-form mistake is not a rounding error: at the low end it is $600, at the high end $3,400, and that is before any state penalty or the cost of fixing the mess. That is the real cost of discovering in late January that you have no IRIS access.
IRIS, explained without the jargon
IRIS is the IRS’s modernized system for receiving certain information returns electronically. It covers the 1099 series plus Forms 1097, 1098, 1042-S, 3921, 3922, 5498, and W-2G. It does not cover everything with a number on it:
- W-2s are not filed through IRIS. Employers file those with the Social Security Administration’s Business Services Online.
- ACA forms are not filed through IRIS either. They go through the IRS’s AIR system.
IRIS has two intake channels, and picking the right one is the single most useful decision in this whole transition.
Channel 1: the IRIS Taxpayer Portal (most small filers)
The Taxpayer Portal is a free, web-based filing system aimed at smaller filers. You can enter data manually or upload a CSV, e-file up to 100 returns at a time, download payee copies for distribution, keep records of completed and filed forms, save issuer information for reuse, run basic validation before submission, and file corrections or request automatic extensions.
If you file, say, 12 subcontractor 1099s a year, this is your channel. You do not need filing software, and you do not need to pass an assurance-testing process. You do need an IRIS Taxpayer Portal TCC, and you need an EIN to apply for it.
Channel 2: IRIS Application to Application, or A2A (high volume or software-driven)
A2A is the system-to-system channel for filers with their own software or a third-party provider. It accepts up to 100 MB at a time and can handle thousands of returns. The trade-off is setup: a direct A2A filer needs an A2A TCC, an API Client ID, the current schema package, and successful transmissions through the IRS Assurance Testing System before production filing. Since October 7, 2026, IRIS transmissions for tax years 2022 through 2026 must use SchemaVersionNum 5.0.7 — a detail your software vendor handles, but one worth confirming if you built your own filing tool.
If your accounting software or payroll provider files for you, ask them one question this week: “Are you filing my 2026 1099s through IRIS, and is there anything you need from me?” If the answer is yes and they need nothing, your transition may already be done. Get that answer in writing — an email counts — because “I assumed my software handled it” is a poor defense in February.
The 10-form e-file rule, still in force
Starting with tax year 2023, if you file 10 or more information returns in aggregate, you must file them electronically. Different information-return types are aggregated when counting toward the threshold, and W-2s count toward the total even though they are filed with the SSA rather than through IRIS. A freelancer with six 1099-NECs and five W-2s, for example, is over the line and must e-file.
That rule is why “I will just paper-file” is not a fallback for most growing freelance businesses. Paper filing is still available below the threshold, but it is slower, easier to get wrong, and it does not solve the TCC problem if you cross the threshold next year.
Your week-by-week switch plan
Here is the plan I would follow if I were a freelancer with a dozen subcontractors and no IRIS account yet. Adjust the dates to your own volume, but do not skip a step.
This week (by November 9–12): decide and apply
- List every non-employee you paid in 2026. Pull it from your bank, PayPal, Wise, or bookkeeping software — not from memory. Total it per person, for the full year, including payments you expect to make in November and December.
- Apply the $2,000 threshold. Anyone under $2,000 for the year drops off your 1099-NEC list (keep the records anyway). Anyone at or over it stays.
- Collect W-9s now. If you are missing a W-9 for anyone on the list, request it today. Chasing a taxpayer identification number in January, when the contractor is busy and you are up against a deadline, is a miserable experience. Backup withholding rules apply if you cannot get one, and that is a conversation to have with a CPA, not a guess to make alone.
- Decide your channel. Under about 100 returns, choose the Taxpayer Portal. Over that, or if you already use filing software, choose A2A and loop in your vendor.
- Apply for your IRIS TCC. You need an EIN. The IRS says processing can take up to 45 business days, and processing times vary. Treat that as an estimate, not a promise, and start the clock as early as you can.
Mid-November to mid-December: set up and test
- Confirm your TCC approval. Do not assume the application went through. Log in, check the status, and save the approval notice.
- Enter your issuer information in the portal and save it for reuse. This is the unglamorous step that saves you an hour in January.
- Reconcile your payee list against your books one more time. Add December payments as they happen. A contractor who crosses $2,000 with a December invoice belongs on the list even if they were under it in October.
- Confirm your software vendor’s IRIS readiness if you file through software. Ask specifically about the schema version for tax year 2026 and about their filing calendar.
January: file, then verify
- File 1099-NECs by February 1, 2027. Send recipient copies and file with the IRS by the same date.
- Download and keep your acceptance records. IRIS keeps records of completed and filed forms — save your own copies too, outside the portal.
- Distribute payee copies and keep proof. A contractor who says they never received a form is a problem you can prevent with a sent-email record.
If you miss the TCC window
If you start late and your TCC is still pending in January, do not wait silently. Talk to a CPA or a filing service that already holds an IRIS TCC — they can file on your behalf while your own application is pending. Filing late because you were waiting for your own code is still filing late. The penalty clock does not pause for an application queue.
Three mistakes I expect to see a lot of this season
Mistake 1: assuming the FIRE TCC works in IRIS. It does not. This is stated in every IRS transition notice and every reputable guide, and it will still catch people. The codes are system-specific. A FIRE TCC is a souvenir after November 19.
Mistake 2: assuming the software handles it without checking. Most reputable providers have moved to IRIS. Some smaller tools have not, or have moved only for certain form types. One email this week prevents a February surprise.
Mistake 3: rebuilding the payee list from the old $600 threshold. If you file for everyone you paid $600 or more, you will file forms you do not need, create confusion for contractors who then wonder why they received a form for $700, and waste portal time. If you file only for people over $600 but miss the aggregation rule — four $600 invoices to one person — you will miss a form you do owe. The per-payee annual total is the test. Use it.
What this costs, honestly
For a small filer using the Taxpayer Portal directly, the cash cost is close to zero: the portal is free, and the TCC application is free. The real cost is time — an hour or two to apply, set up issuer information, and enter forms — plus the cost of getting it wrong.
For a filer using a service or software, expect the provider’s normal per-form or subscription fee, unchanged in principle by the IRIS move. If a provider tries to charge a large one-off “IRIS migration fee” for a small filing, get a second quote. The portal exists precisely so small filers are not held hostage by a migration surcharge.
And the cost of doing nothing? At $60 to $340 per late or missing form, a ten-form filing that slips by a month can cost more than a year of bookkeeping software. That math usually settles the “is this worth an afternoon” question.
How this fits your year-end freelancer checklist
This transition sits alongside the other year-end jobs that actually move money. Quarterly estimated taxes are the obvious companion piece — if you have not already squared away your fourth-quarter estimate, our walkthrough of the freelancer quarterly system is here: quarterly estimated taxes for freelancers. The two jobs share the same source data: your 2026 income and your 2026 payments to others. Do them in the same sitting and you will reconcile both faster.
The broader point is about how freelance businesses grow. The year you hire your first subcontractor, tax filing stops being something clients do to you and starts being something you do for others. That is a good problem — it means you have more work than you can do alone — but it comes with a filing obligation that does not wait for you to feel ready. IRIS is just the new mailbox. The obligation is the same one you already had. Get the code, file on time, and January gets a lot quieter.
This article is general information, not tax or legal advice. Confirm your filing obligations, thresholds, and deadlines with a qualified tax professional, and check current IRS notices before acting — transition dates and form instructions can change.
Frequently Asked Questions
Do I need to switch to IRIS if I only receive 1099s from clients?
No. Receiving a 1099 is not filing one. IRIS is for people who submit information returns to the IRS. If you never pay non-employees for business services, you have nothing to file through IRIS, and the FIRE retirement does not change anything for you.
When is the last day to file through FIRE?
November 19, 2026, at 3 p.m. Eastern Time. After the November maintenance window, FIRE stops accepting submissions. From January 1, 2027, IRIS is the only electronic channel for information returns.
Does my old FIRE Transmitter Control Code work in IRIS?
No. FIRE TCCs do not carry over. You must apply for a separate IRIS TCC, and the IRS says a typical application can take up to 45 business days to process, so apply well before the filing season.
Which IRIS channel should a small freelancer use?
The free IRIS Taxpayer Portal, in most cases. It handles up to 100 returns at a time, accepts manual entry or CSV upload, and covers corrections and extensions. A2A is for high-volume filers or those using filing software that transmits system-to-system.
What is the 1099-NEC threshold for 2026 payments?
$2,000 per payee for the full calendar year, up from $600. The test is the annual total paid to one non-employee, not the size of any single invoice. Income remains taxable to the recipient even if no form is required.
When are 2026 1099-NEC forms due?
To recipients and to the IRS by February 1, 2027, because January 31, 2027 falls on a Sunday. Other 1099 forms have their own dates, so check the form you are filing rather than assuming the NEC date applies to everything.