IRS Publication 1220 Updates for Tax Year 2025

The IRS has released the latest updates to Publication 1220 for Tax Year 2025, which governs the electronic filing of information returns. Several significant changes affect how filers should prepare for the next two filing seasons and transition toward the Information Returns Intake System (IRIS). Below is a clear breakdown of what has changed and what filers should plan for now.

Retirement of the FIRE System

The IRS issued a QuickAlert on July 2, 2025 announcing its plan to retire the Filing Information Returns Electronically (FIRE) system. The transition timeline is important for filers:

  • The targeted retirement date is Tax Year 2026 filing in 2027.
  • For the 2027 filing season, all information returns that previously went through FIRE will be processed exclusively through IRIS.
  • The IRS advises filers to begin preparing early. This includes applying for a Transmitter Control Code (TCC) through the IRIS TCC application.

The IRS will continue providing updates through QuickAlerts, IRIS Working Group meetings, and future revisions of Publication 1220. Filers who currently rely on FIRE should make IRIS onboarding a priority.

Image of IRS Publication 1220 Cover
IRS Publication 1220 Cover

Golden Parachute Payments Can No Longer Be Filed Through FIRE

Another major change affects filers submitting Excess Golden Parachute Payments. Prior to tax year 2025, these payments were filed using IRS Form 1099-MISC, but has been moved to IRS Form 1099-NEC, Box 3.

Publication 1220 now states:

  • Golden Parachute payments cannot be filed through FIRE for any tax year including prior year submissions.
  • Corrections for previously submitted FIRE filings must be filed on paper.

If a filer needs to submit 10 or more paper forms, they must request a waiver from electronic filing using Form 8508, Request for Waiver From Filing Information Returns Electronically.

This Publication 1220 change strengthens the IRS focus on shifting all information return processing to IRIS.

Combined Federal and State Filing Program Changes

The Combined Federal and State Filing (CF/SF) program has also been updated:

  • Oregon has been added with state code 41.
  • Missouri has been removed and will no longer participate under code 29.

Filers using CF/SF must update their state mapping and confirm submission requirements with each state directly. State participation in CF/SF does not always cover all form types, so a compliance review is recommended.

Form 1099-Q: Addition of Code for QTP to Roth IRA Transfers

For Form 1099-Q, Payments from Qualified Education Programs, the IRS has added a new update in the Payee B Record, field position 547:

  • Code 2 has been added to report a Qualified Tuition Program (QTP) to Roth IRA transfer.

This reflects recent tax law changes allowing certain rollovers from 529 plans to Roth IRAs within specific limits.

Form 1099-R: New Distribution Code Y for Qualified Charitable Distributions

Publication 1220 adds a new coded value for Form 1099-R reporting. In the Payee B Record at positions 545 to 546:

  • Distribution Code Y has been added to identify Qualified Charitable Distributions (QCDs).

This update aligns 1099-R electronic filing with legislative guidance on QCD reporting.

Image of Form 1099-R - Copy A, Tax Year 2025
Image of Form 1099-R – Copy A, Tax Year 2025

What Filers Should Do Next

With these changes, filers and transmitters should:

  • Review the updated Publication 1220 and IRS form instructions for changes.
  • Begin transitioning internal systems toward IRIS before the FIRE retirement in 2027.
  • Confirm whether any Golden Parachute reporting applies and switch to IRIS immediately.
  • Update CF/SF state participation tables and notify affected clients or partners.
  • Implement updated field codes for Forms 1099-Q and 1099-R in software and file layouts.
  • Monitor the IRS for ongoing QuickAlerts and revision updates.

BoomTax, The Boom Post, and its affiliates do not provide tax, legal or accounting advice. This material has been prepared for informational purposes only, and is not intended to provide, and should not be relied on for, tax, legal or accounting advice. You should consult your own tax, legal and accounting advisors prior to engaging in any transaction.

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