Pressing issues for tax leaders transitioning to the IRS IRIS platform

1. Put a documented transition plan in place now

Under FIRE, many organizations concentrated their efforts near the filing deadline. That can mean assembling a file, uploading it and addressing any issues later. However, the IRIS process requires a broader readiness model and definitive action steps now. These may include a new IRS connection, revised data structure and transmission testing as well as an IRIS-specific Transmitter Control Code (TCC) that alone can take 45 days to receive from the IRS. The responsibilities for this change touch tax, finance, accounts payable, technology and procurement functions as well as external providers. In preparation, tax leaders should begin by establishing executive ownership and a documented transition plan rather than delegating the change solely to their technology departments. Planning should include the end-to-end reporting process, identifying decision rights and assigning accountable owners for data, testing, approvals, corrections and filing continuity.

2. Establish data readiness for filing readiness

The IRIS process places greater pressure on the quality and structure of original source data. Incomplete taxpayer information, name-and-TIN mismatches, inconsistent address fields or unsupported formats can interrupt transmission and create a larger remediation workload. Leaders should require an early data assessment across relevant 1099 reporting for vendors and suppliers. In addition, leaders should place a focus on completeness and accuracy, confirm transmission rules and test representative files, including high-volume and exception scenarios. Embed the new controls earlier in vendor onboarding and payment processes so that the organization is not relying on year-end cleanup.

3. Set internal milestones ahead of statutory deadlines

Readiness for successful 1099 reporting depends on more than the internal project schedule. TCC processing, platform testing, approvals and provider capacity all introduce dependencies that tax teams do not fully control. If one stage slips, the remaining window to resolve errors, retest and obtain approval narrows quickly. Potential consequences may include rejected or delayed filings, penalties, additional manual work and stakeholder concerns. Leaders should consider setting internal milestones ahead of statutory deadlines, maintaining a visible risk register and taking time to define escalation triggers. A contingency plan should cover connection failure, data rejection, delayed approval and correction of prior year returns after FIRE is unavailable.

4. Select the right support for your organization

For organizations that are already behind, outside support in the form of managed services to compress their readiness timeline is a strong potential solution. But when selecting a managed services provider, remember that a successful transition to the IRIS platform is more than a technology switch. Beyond access to the IRIS platform, consider the knowledge and scalable resources that a potential information reporting and withholding (IRW) managed services provider can offer. As you do this, look for their ability to accept and prepare raw data, identify issues proactively, support testing, resolve filing errors, manage IRS interactions and provide transparent status reporting through submission and correction.

Tax leaders also might want to assess providers against outcomes, including implementation speed, production readiness, ability to handle exceptions, capacity to scale, data security, plus service-level commitments and evidence of successful IRIS validation. Before any selection is made, determine where accountability sits when data fails validation or filing windows tighten.

The window for a smooth IRIS transition is closing. Tax leaders who take the necessary steps now and secure the right managed services support may be better positioned to protect filing continuity, reduce risk and enter the 2027 tax year ready to execute.