Your clients are about to ask you the same question: “What do we need to do about this FIRE thing?” Some already have. The IRS FIRE system shuts down on December 31, 2026, and every business that files 1099s electronically needs a new path. As their CPA, you’re the person they trust to explain what’s happening and what to do about it.
This guide is built for accounting professionals. It covers what’s actually changing, what your clients need to hear from you, and how to position your firm as the one that had this handled months before the deadline.
The 60-Second Briefing for Your Clients
Most clients don’t need a technical deep-dive. They need to understand three things:
- The IRS is replacing its electronic filing system. FIRE (the system used for 1099s since the 1990s) shuts down permanently on December 31, 2026. Its replacement is called IRIS (Information Returns Intake System).
- This affects 1099 filing, not W-2 filing. W-2s go through the SSA’s BSO system, which is unchanged. 1099s – NEC, MISC, INT, DIV, and all other information returns – must move to IRIS.
- They may not need to do anything – if their CPA or filing provider handles the transition for them. This is where you come in.
That third point is the one that matters most. Clients who file through your firm are looking to you for reassurance. Clients who file on their own need your guidance on next steps.
What’s Actually Changing (And What Isn’t)
CPAs need to understand the technical reality more deeply than their clients do. Here’s the full picture:
What’s changing
- Filing platform: FIRE goes offline. IRIS becomes the sole electronic filing channel for information returns (1099s, 1098s, 5498s, 3921s, and others).
- File format: FIRE used fixed-width flat text files (Pub 1220 format). IRIS uses structured XML. Files that worked with FIRE cannot be uploaded to IRIS directly.
- Authentication: FIRE used a TCC (Transmitter Control Code) with username/password login. IRIS uses a different TCC process with modern authentication.
- Corrections workflow: The process for filing corrections through IRIS differs from the FIRE process.
What isn’t changing
- W-2 filing: W-2s still go through SSA’s BSO (Business Services Online). Completely unaffected.
- Form types: The same 1099 forms exist. 1099-NEC, 1099-MISC, 1099-INT, 1099-DIV – all the same forms, same data, same deadlines.
- Filing deadlines: January 31 for 1099-NEC, March 31 for most other 1099s. No changes.
- Penalty structure: Same penalties for late filing, incorrect returns, and failure to file. No IRIS-specific penalties – but no leniency either.
The Three Client Scenarios You’ll Encounter
Not every client needs the same advice. Here’s how to triage:
Scenario 1: “You file our 1099s for us”
These clients need reassurance, not instructions. They want to hear: “We’ve already prepared for the transition. Your filing will go through the new system automatically. Nothing changes on your end.”
For this to be true, your firm needs a filing provider that supports IRIS. If you’re still using a FIRE-dependent workflow – uploading Pub 1220 flat files to a system that transmits through FIRE – you need to migrate your own process first. More on that below.
Scenario 2: “We file our own 1099s through FIRE”
These clients need a direct conversation. Their existing workflow will stop working on January 1, 2027. They have three options:
- Build an IRIS integration – requires XML development, new TCC application, OAuth authentication, and sandbox testing. Realistic for large IT-staffed organizations, not for most small-to-mid businesses.
- Use IRIS Taxpayer Portal – the IRS free web-based option. Manual data entry, suitable for businesses filing a small number of returns. Not practical above a few dozen forms.
- Use a filing provider – upload data, the provider handles IRIS transmission. This is the path that makes sense for the vast majority of businesses.
Your advisory value here is helping the client understand which option fits them. For most, it’s option 3. Your role as their CPA is to recommend a provider and help them get set up before Q4.
Scenario 3: “We didn’t know about this”
This is more common than you’d expect. Many small business owners don’t follow IRS system changes. They’ll hear about this in October or November – possibly from you, possibly from a panicked Google search. Being the one who tells them early (with a plan) is significantly better than being the one they call in January asking why their filing didn’t go through.
What Your Firm Needs to Do Now
Before you can advise clients, your own house needs to be in order. Here’s a checklist for accounting firms:
1. Audit your current filing workflow
How does your firm currently submit 1099s? If you’re using a filing provider, contact them and confirm they’re IRIS-ready. If you’re generating FIRE flat files and transmitting directly, your workflow needs to change.
2. Choose your IRIS path
For most accounting firms, the right answer is a filing provider that handles the IRIS plumbing. You don’t want to be in the business of maintaining XML schema compliance, OAuth token management, and IRS API integrations. You want to upload data and get acknowledgments back.
BoomTax is built for exactly this use case. You upload your data – including FIRE-format flat files – and we handle the conversion to IRIS XML and the transmission. Your existing data export process doesn’t need to change.
3. Test before tax season
Don’t wait until January to test your new workflow. Upload a test batch now or in Q3. Confirm the data maps correctly. Identify any issues while there’s time to resolve them, not when you’re under deadline pressure with client returns stacking up.
4. Update your client communications
Add the FIRE shutdown to your next newsletter, quarterly update, or client touchpoint. A proactive mention now prevents reactive calls in December. Use the language in the callout box above – keep it simple, keep it reassuring.
5. Consider the growth opportunity
Some of your clients file their own 1099s. The FIRE shutdown is going to disrupt their workflow. Offering to handle their 1099 filing – using a provider like BoomTax as your backend – is a service expansion that benefits both of you. They get reliability during a confusing transition. You get a new recurring engagement.
The FIRE-Format File Question
This is the question that trips up the most firms: “We’ve been exporting FIRE flat files from our tax software for years. Do we need to change our export process?”
The answer depends on your provider. If you’re building a direct IRIS integration, yes – you’ll need XML output. If you’re using BoomTax, no. BoomTax accepts FIRE-format flat files (Pub 1220) and converts them to IRIS-compliant XML automatically. Your data export process stays exactly the same.
This is a significant operational advantage. It means the transition for your firm can be as simple as uploading files to a different platform. Same data, same exports, same process – different destination. Learn more about how FIRE-format file upload works.
Timeline: What to Do When
Here’s a recommended timeline for CPA firms:
- Now (July 2026): Audit your firm’s filing workflow. Confirm your provider supports IRIS. If switching providers, start evaluating now.
- August-September: Send client communications about the FIRE shutdown. Offer to handle filing for clients who do it themselves.
- October: Run a test batch through your new IRIS workflow. Resolve any data mapping issues.
- November: Clients who file directly should have applied for their IRIS TCC by now. If they haven’t, strongly recommend a provider as backup.
- December: Final confirmation that all systems are ready. FIRE shuts down December 31.
- January 2027: File through IRIS. 1099-NEC due January 31.
Frequently Asked Questions
Do CPAs need their own IRIS TCC to file on behalf of clients?
If you’re filing directly through IRIS, yes – you need a TCC as a transmitter. If you’re using a filing provider like BoomTax, no. The provider files under their TCC. You upload data to the provider, and they handle the IRS transmission. Most accounting firms use a provider and don’t need their own TCC.
Our tax software vendor says they’ll handle the IRIS transition. Is that enough?
It might be – but verify. Ask specific questions: Does their software already file through IRIS? What form types? Have they completed successful test filings? If the answers are “we’re working on it” or “it’ll be ready by year-end,” that’s a yellow flag. Have a backup plan in place by October.
Will small clients filing fewer than 10 returns need to use IRIS?
Small filers can use the IRIS Taxpayer Portal for free. It’s a web-based interface for manual data entry – no TCC or technical setup required. For clients with 10 or fewer returns, this is a reasonable option. Above that, the manual entry becomes impractical and a filing provider is the better path.
How should we handle clients who are behind and won’t act until December?
Document your advisory. Send the recommendation in writing, ideally by September. If a client chooses to wait, that’s their decision – but your firm should have a recommended provider ready to go. BoomTax accounts can be created and used immediately, so even a December start is workable if the data is ready.
Are there any IRIS-specific fees or costs we should tell clients about?
IRIS itself is free to use – there’s no IRS fee for filing through the system. Filing provider costs vary. BoomTax pricing is per-form with volume discounts, and there’s no subscription or platform fee. Clients who currently file through FIRE for free should understand that building a direct IRIS integration has significant development costs, while using a provider has a predictable per-form cost.
Position Your Firm Ahead of the Curve
The FIRE shutdown is going to create confusion. Clients will Google it, read incomplete information, and worry. The firms that come out ahead are the ones that address this proactively – with a clear message, a tested workflow, and a plan that’s already in motion.
For a comprehensive walkthrough tailored to accounting professionals, see our IRIS Filing Guide for CPAs and Accountants. And for the full picture of the FIRE-to-IRIS transition, our pillar page has everything in one place.
Or skip the research and start testing. Create a free BoomTax account, upload a batch of test data, and confirm your January filing workflow works – before your clients even think to ask.
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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