FIRE will be replaced by IRIS and IDES system
On April 20, 2026, we informed that the IRS plans to retire the Filing Information Returns Electronically ("FIRE") platform for electronic transmission of 1042-S and 1099 Forms and replace it with the Information Returns Intake System (“IRIS”). Recently, the IRS specified that, starting with filing season 2027 (for tax year 2026 onwards and amendments of previous tax years), the FIRE platform will be retired. The IRIS platform was introduced as replacement for FIRE.
One open question the IRS now answered was how forms should be amended that were previously filed through FIRE. The IRS informed that amendments of forms filed through FIRE will be filed through IRIS (or IDES, see below). The Filer will be able to indicate that the amendment concerns a form that was previously filed through FIRE via an XML element.
In addition, and importantly, the IRS also informed that foreign filers, who until now were not able to register with IRIS due to system restriction of not accepting U.S. citizens as responsible officials, will be able to register with the International Data Exchange Service (IDES), previously primarily used to file the FATCA reporting, to obtain a Transmitter Control Code (TCC) in the so-called "Foreign Filer TCC Registration System" to fulfill their reporting obligations. Foreign filers will only be able to access the Foreign Filer TCC Registration System if they have valid accounts with ID.me or Login.gov. The IRS will provide the link for registration with ID.me or login.gov in the Foreign Filer TCC Registration System homepage (currently unavailable).
The Foreign Filer TCC Registration System will require foreign filers to acquire a Global Intermediary Identification Number (GIIN) for the sole reason to be able to secure a TCC. The acquired GIIN in this context is to be referred as TCC GIIN. Subsequently, the foreign filer will be able to enroll in IDES using the TCC and TCC GIIN.
Although the IRS has addressed some of the obstacles that IRIS posed for foreign filers, the new IDES transmission option remains challenging. Foreign filers, or their system providers, will face very short deadlines to implement the new reporting process and produce Forms 1042-S if they intend to generate the 1042-S XML files from their systems. Several important points also remain unanswered, including the release date of the Foreign Filer TCC Registration System, how and when the IRS will make the XML schema publicly available, the availability of publications and instructions, the requirements for a valid IDES certificate, the applicable business rules, and the instructions for IDES enrollment.
To overcome these challenges, we are happy to present filers with our IRIS Transmission Service, which entails:
the submission of the request of time extension for filing Forms 1042-S and 1099 via IRIS (Form 8809),
the validation of the template filled out by the withholding agent,
the generation of the Forms 1042-S and Forms 1099 as XML-File and PDF (Recipient Copies B, C and D) according to the template,
the submission of the information return to the IRS with our IRIS login via the A2A platform, and
the forwarding of the submitted Forms as XML-File and PDF (Recipient Copies B, C and D) and of the IRS response as XML-File.
Update from July 8, 2026: The IRS published Publication 6167 instructing Foreign Filers how to register with IDES for the transmission of Forms 1042-S and 1099 through IDES for the tax years 2026 and subsequent years. In summary, Foreign Filers are required to perform the following steps for enrollment according to Publication 6167:
Registration with login.gov or ID.me: The Foreign Filer must appoint employee(s) as Responsible Officer (“RO”) and the Point of Contact of the Foreign Filer for purposes of filing through IDES. The RO is required to maintain the registration up-to-date and serve as IRS main contact for purposes of IDES filings. The email address of either one of these persons must be used in order to create an account with login.gov or ID.me
Set Up a Foreign Filer TCC Account: A Foreign Filer TCC Account must be created through the Foreign Filer TCC Registration page. You will be informed of your Foreign Filer ID, which should be recorded in order to be able to access the account in the future.
Complete and Submit the Registration for a TCC Global Intermediary Identification Number (TCC GIIN): The Foreign Filer’s name must be filled in and match the organization’s name associated with the EIN in the records of the IRS. After review and submission of the registration, the IRS will process the registration and confirm its approval.
Approval of Registration for TCC GIIN: The RO will be notified by email about account updates and TCC GIIN approval messages. Once a TCC GIIN is issued, the RO will be able to request a TCC for electronic transmission of Forms 1042-S and 1099 through IDES.
Request of a TCC: Upon receipt of the TCC GIIN, the RO shall sign in to the Foreign Filer TCC Registration system using the Foreign Filer ID and request a TCC under “Available Account Options”. After successful submission of the request, the RO will be able to look up the TCC in “View TCC” under “Available Account Options”
Enrollment in IDES: After receipt of the TCC GIIN and TCC, the IRS will require three to six weeks for processing. During this time, the Foreign Filer shall purchase the Authorized Security Certificate from an approved Certificate Authority which will be required as part of the enrollment process. The RO will then enroll with IDES as the Account Administrator using the TCC GIIN and the certificate.
The IRS Working Group Meeting stated that the final XML schema for tax year 2026 should be tentatively available in August. It is not clear if the XML schema for IRIS will be the same as the one used for IDES and if the schema for IDES will be made public. Currently, the XML schema for IRIS can only be retrieved by organizations enrolled in IRIS in the role of Software Developer.
If you are interested in engaging us for this transmission service or require our assistance with enrollment onto IDES, please contact us. If you are already a valued client of our services, we will contact you within the next weeks separately.