Electronic filing is now a requirement for most payroll companies that handle federal tax forms. Starting with tax year 2023, the Internal Revenue Service requires employers filing 10 or more information returns, such as Forms 1099 and W-2, to submit them electronically. This update affects many organizations, including small businesses, payroll service providers, and tax professionals. Companies must navigate the IRS-approved electronic filing process to comply and obtain a Transmitter Control Code (TCC).

A Transmitter Control Code (TCC) is a unique identifier that enables secure access to IRS electronic filing platforms. The two primary systems are the FIRE system and the IRIS portal, each supporting different form types and user needs. Employers must identify the system that aligns with their reporting obligations and ensure that all data is accurate before submitting returns. Electronic filing reduces delays, improves validation, and simplifies the correction process when errors occur.

To get started, the IRS provides a complete overview of the electronic filing requirements for information returns, outlining who must file electronically and how to access the appropriate platform. The following sections will guide you through each step of the electronic filing process.

Who Needs to File Electronically and Why It Matters

Federal electronic filing requirements are no longer limited to large organizations. As of tax year 2023, the IRS mandates that any employer filing 10 or more information returns must submit them electronically. This rule applies to the total number of returns across all form types, including Forms 1099-NEC, 1099-MISC, W-2, 1042-S, and others. 

The threshold is calculated based on the aggregate number of forms, regardless of whether they are of the same type or filed using different platforms. Once the 10-form threshold is reached, paper filing is no longer permitted without an approved waiver.

Employers Required to File Electronically

All businesses that meet or exceed the 10-form threshold must comply with electronic filing rules. This includes corporations, partnerships, sole proprietorships, nonprofits, government agencies, and tax-exempt organizations. Entities filing on behalf of others, such as payroll service providers and tax professionals, must also submit returns electronically. The rule applies even if the forms are filed in batches or through different IRS systems.

Recipients and Filing Responsibilities

The requirement extends beyond issuing forms to recipients. Employers must ensure that all returns sent to the IRS and to recipients, such as employees and independent contractors, are accurate and delivered by the IRS-prescribed due dates. Failing to do so can result in penalties, especially if electronic filing is required but not followed. The responsibility includes verifying each recipient's information and ensuring the secure handling of sensitive tax data.

Entities meeting the threshold must file electronically to comply with IRS rules. The IRS applies these rules uniformly to all entities, regardless of industry or filing method used in previous years. Meeting these obligations is essential to maintaining compliance, avoiding delays, and reducing exposure to penalties associated with noncompliance.

What Is a Transmitter Control Code (TCC)?

A Transmitter Control Code (TCC) is a required identification code to file tax forms electronically through IRS-approved systems. The IRS assigns the TCC to businesses, payroll providers, and authorized transmitters to ensure that only verified users access its secure electronic filing platforms. The code is essential for transmitting Forms 1099, W-2, and other information returns, and serves as the foundation for managing the tax filing process electronically.

  • TCC Function and Purpose: A TCC connects the filer’s IRS account to the system for submitting tax returns. It validates the organization’s authority to participate in electronic transmission.

  • TCC Required for Access: The IRS does not allow filers to use the FIRE or IRIS system without an approved TCC. Access to each platform becomes available only after the IRS issues the TCC and links it to the appropriate account.

  • Consent and Identity Verification: Applicants must verify their business identity and explicitly consent during registration. This includes confirming the applicant’s role within the organization.

  • Login Credentials and IRS Account Setup: Before submitting a TCC application, users must create an IRS online account and complete multi-factor login verification to secure access.

  • Authorized Signatory Obligations: A responsible person must sign the application electronically, and their authority must be validated during the account creation process.

  • System-Specific Use: Each TCC corresponds to a specific IRS platform. The FIRE system and IRIS portal require their own TCC and do not permit crossover use.

  • Ongoing User Access Management: User access must be appropriately maintained once issued. Organizations can add users, but only verified individuals can initiate or modify electronic filings.

A TCC is the first step toward gaining system access and ensuring secure and compliant electronic filing. Establishing this authorization early prevents delays and allows sufficient time to prepare for submission deadlines.

Filing Information Returns Electronically: FIRE vs. IRIS

The IRS supports two primary systems for transmitting information returns electronically: the Filing Information Returns Electronically (FIRE) system and the Information Returns Intake System (IRIS). 

Each platform is designed to accommodate specific filing needs, and choosing the appropriate system depends on the filer’s role, the form types being submitted, and the volume of returns. While both platforms meet federal e-filing standards, their functionality, interface, and user requirements differ significantly.

Platform Overview

  • Supported Form Types
    • FIRE System: Forms 1099 series, 1042-S, W-2G, 5498, 3921, 3922, 8955-SSA, 8027
    • IRIS Portal: Most Forms 1099 (including NEC, MISC, INT, DIV, etc.)
  • System Access
    • FIRE System: Requires a TCC, specialized software, and IRS formatting knowledge
    • IRIS Portal: Requires a TCC, accessible through a secure IRS web login
  • User Interface
    • FIRE System: Text-based file uploads only, no direct form entry
    • IRIS Portal: Web-based interface allowing both manual form entry and file upload
  • Validation and Feedback
    • FIRE System: Feedback is delayed, provided via email or file status updates
    • IRIS Portal: Provides real-time error feedback and form validation
  • State Filing Options
    • FIRE System: Supports the Combined Federal/State Filing Program
    • IRIS Portal: No state integration available
  • Best For
    • FIRE System: High-volume filers, payroll providers, CPAs, and software-driven workflows
    • IRIS Portal: Small to mid-size businesses and first-time electronic filers
  • The FIRE system supports high-volume filers such as large employers and service providers managing thousands of forms and using advanced software to format and upload files. This system requires technical familiarity with IRS data layout standards and managing file rejections and status codes outside the platform. The IRS Publication 1220 specifications provide the formatting requirements for FIRE-compatible files.

    The IRIS portal supports filers who prefer a simplified and secure submission process. It allows manual data entry and .csv uploads, and its interface provides immediate validation for common data issues. Users can also manage their IRS login credentials and track submission status directly within the portal.

    Selecting the right system depends on organizational structure, available resources, and filing volume. FIRE and IRIS are valid solutions, but understanding their differences ensures a smoother tax reporting process and helps prevent late or rejected submissions.

    Applying for a TCC Through the IRS

    A Transmitter Control Code (TCC) is mandatory for accessing any IRS platform to file information returns electronically. Whether using the FIRE system or the IRIS portal, every organization must first obtain a TCC specific to its intended system. 

    The application process involves identity verification, organizational validation, and digital authorization through a secure IRS login. Filers must complete these steps before tax deadlines to avoid processing delays or failed submissions.

    Step 1: Create an IRS Account and Secure Login Access

    • Establish an IRS account using the agency’s identity verification system.

    • Provide personal information, including a valid phone number and email address.

    • Complete multi-factor authentication and secure password creation.

    • Verify your identity with acceptable documents such as a driver’s license or passport.

    • Ensure the individual applying holds proper authority to act on behalf of the organization.

    Step 2: Choose the Correct TCC Application Based on System

    • Use the IRIS portal for most 1099 form types, including NEC, MISC, INT, and DIV.

    • Select the FIRE system application if filing additional forms such as 1042-S or W-2G.

    • Confirm the selected system matches the intended submission platform.

    • TCCs are system-specific and cannot be used across multiple platforms.

    Step 3: Complete the Online Application

    • Access the IRIS application for TCC through the IRS website.

    • Enter your legal business name, EIN, and business structure details.

    • Designate at least one Responsible Official and provide all required contact information.

    • Identify the form types your organization will file and each user's role.

    • Sign electronically using the IRS account credentials associated with the application.

    A TCC requires preparation, accuracy, and an understanding of IRS system requirements. Beginning the application process early helps prevent delays and provides time to address verification issues. Once approved, the TCC becomes the key credential for securely transmitting electronic returns and fully complying with IRS standards.

    Preparing to File: What Payroll Providers Need

    Before initiating any electronic submission, payroll companies must gather all required organizational data, form details, and system credentials. Whether FIRE or IRIS, IRS systems depend on structured inputs that align precisely with the agency’s format and validation requirements. 

    Failure to prepare these elements correctly can delay filings, trigger rejection codes, or result in incomplete transmissions. Readiness begins with verifying entity and recipient information and ensuring that all access and technical requirements have been satisfied.

    Organizational and IRS Account Setup

    • Confirm that the legal business name matches IRS records exactly, including punctuation and spacing.

    • Validate the Employer Identification Number (EIN) assigned to the filing entity.

    • Ensure IRS account credentials are active and linked to the appropriate Responsible Official.

    • Assign and record access roles within the account, including contacts or delegates.

    • Secure login credentials using a unique, high-strength password not shared across systems.

    Recipient and Form-Level Data Requirements

    • Gather accurate recipient details, including name, address, and taxpayer identification number (TIN).

    • Use an IRS-compatible CSV template when uploading forms in bulk, ensuring headers and formatting follow IRS standards.

    • Identify the correct form type for each payment category. This includes Forms 1099-NEC, 1099-MISC, and W-2.

    • Validate each entry before importing, paying attention to date fields, decimal formatting, and required codes.

    • Review saved data for accuracy, verifying that no entries remain incomplete or misclassified.

    A thorough preparation process supports compliance, minimizes submission errors, and strengthens the reliability of each return. Payroll providers who complete these steps in advance are better positioned to transmit returns efficiently and correct errors proactively. Consistency in data management also promotes smooth participation in annual filing cycles.

    E-File Forms Through FIRE or IRIS

    Once all required information has been verified and correctly formatted, payroll providers may begin submitting returns through the FIRE or IRIS system. Each IRS-approved platform has a unique workflow and requires precise adherence to procedural and technical standards. Organizations should follow a structured approach tailored to the system selected to avoid transmission errors and rejections.

    Step 1: Log in to the Correct System

    Access the chosen system, the FIRE or IRIS platform, using the appropriate Transmitter Control Code (TCC) and verified IRS account credentials. Confirm that the login information is current and functioning properly. Ensure that all authorized individuals within the organization have been granted the necessary permissions to initiate the electronic filing process.

    Step 2: Prepare the Data File or Use Direct Entry

    Prepare the upload file for FIRE users using the current IRS Publication 1220 format. Validate that each data field conforms to the record layout specifications, including employer details, recipient information, and dollar amounts. For IRIS users, choose between uploading a formatted .csv file or completing direct data entry within the online portal.

    Step 3: Submit the File or Entry

    Follow the submission prompts to upload the file to the system. Before uploading, confirm that the correct form type has been selected. Upon successful transmission, the system will assign a timestamp and confirmation ID.

    Step 4: Monitor Submission Status

    After submission, review the system-generated feedback. The IRIS platform provides real-time validation messages, while the FIRE system delivers results through status files or email. Watch for indicators of acceptance, pending review, or rejection due to format or data issues.

    A methodical submission process helps reduce delays and ensures that the IRS receives and records filings. Careful review of confirmation messages and prompt resolution of flagged issues contribute to a smoother and more compliant tax filing experience.

    Fixing Errors: What to Do If Returns Are Rejected

    When an electronically filed return is rejected, the IRS system will issue a status update identifying the issue and providing a reference code. Whether using FIRE or IRIS, payroll providers must address these issues promptly to maintain compliance and meet critical deadlines. 

    Most rejections stem from formatting errors, mismatched taxpayer data, or omitted required fields. Responding systematically to each rejection improves accuracy and prevents recurring filing issues.

    Common Rejection Causes and Solutions

    Incorrect TIN or Name Mismatch: Before resubmitting, compare the taxpayer identification number (TIN) and name combination against IRS records. Use the IRS TIN Matching tool to verify that names and taxpayer identification numbers align with IRS records.

    Formatting Errors in Uploaded Files: Review the original file format. For FIRE, confirm that each field follows Publication 1220 layout rules. For IRIS, verify column headers and cell formats in the .csv file.

    Missing Required Data Fields: Ensure all required fields, including account numbers, recipient addresses, and payment amounts, are present and complete.

    Duplicate Return Submission: Do not attempt to refile the same return without identifying whether the original was accepted or rejected. Duplicate submissions will trigger further errors.

    Incorrect Form Type Selection: Double-check the form type selected before submission. Using the wrong type, such as filing a 1099-MISC instead of a 1099-NEC, will result in a rejection notice.

    Filing corrections should be approached with accuracy and timeliness. Reviewing the rejection notice, understanding the associated code, and correcting the file precisely reduces the risk of additional penalties. Each submission must be verified before resending, ensuring data quality and compliance with IRS specifications.

    IRS Penalties and How to Avoid Them

    The IRS imposes structured penalties for information returns filed late, submitted inaccurately, or provided to recipients after the required due date. These penalties apply per return and are assessed in tiers based on how many days have passed since the filing deadline. The longer the delay or the more severe the error, the higher the penalty amount. Employers and payroll providers must closely monitor deadlines and verify all filings to avoid incurring costly fines.

    Failure to electronically file when required may result in immediate penalties, even if the return is accurate and timely in other respects. The mandatory e-filing threshold of 10 or more information returns applies to the total number of returns filed across systems. For example, a business submitting six Forms 1099-NEC and four Forms W-2 must file all electronically. Filing paper returns without an approved waiver may result in penalties, even if the organization previously filed by mail.

    Incorrect or missing recipient information, such as taxpayer identification numbers, names, or addresses, may also lead to penalties. The IRS evaluates these issues separately from late filings. Organizations must review all recipient data before transmission, conduct internal audits, and apply validation tools to confirm data accuracy before submission. Additionally, providing incorrect statements to recipients can lead to a separate assessment even if the IRS copy is correct.

    Avoiding penalties requires more than timely filing. It demands consistency in reviewing deadlines, validating data, submitting forms through the correct platform, and furnishing accurate copies to all recipients. Employers implementing a calendar-based compliance system and assigning clear responsibilities for each filing stage are more likely to maintain error-free returns. Proactive preparation reduces the risk of oversight and contributes to year-round compliance.

    How to Outsource 1099 and W-2 E-Filing Efficiently

    Outsourcing the electronic filing can be a practical and cost-effective strategy for payroll providers, employers, and accounting teams managing high-volume information returns. The IRS permits third-party transmitters to submit returns on behalf of clients, provided they meet registration and system-specific requirements. To ensure compliance and data security, organizations should accurately evaluate potential outsourcing partners and align selection criteria with regulatory expectations and internal goals.

    Step 1: Define Filing Needs and Return Volume

    Identify the form types required for the current tax year, such as 1099-NEC, 1099-MISC, or W-2. Estimate the total number of returns across all clients or business entities. This will determine whether the 10-form e-filing threshold is met and which filing system applies.

    Step 2: Choose a Qualified Third-Party Provider

    Select a provider experienced in handling IRS electronic returns and authorized to use a valid Transmitter Control Code. Confirm that the provider supports FIRE and IRIS platforms, depending on your filing structure—request documentation verifying system compatibility, security protocols, and historical compliance accuracy.

    Step 3: Establish Secure Communication and Account Access

    Work with the provider to create a dedicated filing profile. Assign access roles and clarify how sensitive data will be transmitted and stored. Use encrypted channels for data exchange and confirm multi-factor authentication for login credentials. Maintain internal oversight even when operations are outsourced.

    Step 4: Review and Authorize Before Submission

    Perform a detailed data review before the provider transmits any returns to ensure accuracy. Sign off on each batch of forms, verify recipient details, and confirm that each submission meets IRS formatting standards. Request confirmation upon filing and save all related documentation.

    An experienced outsourcing partner can reduce administrative burden while preserving control over compliance. Structured communication, documented approval procedures, and data validation protocols are essential for successful collaboration.

    E-Filing Best Practices for Long-Term Compliance

    Long-term IRS compliance depends on more than submitting forms during tax season. It requires a structured approach incorporating security, verification, and clearly defined responsibilities. Employers and payroll providers who maintain organized, proactive systems are better equipped to meet requirements, prevent errors, and reduce penalties.

    Key Practices to Support Ongoing Compliance

    • Review all returns before filing: Check for complete fields, correct form types, and matching recipient data. Confirm accuracy in dollar amounts, dates, and formatting.

    • Secure the filing environment: Store and transmit data using encrypted platforms. Limit access to trained individuals and monitor login activity regularly.

    • Maintain strong password security: Enforce complex password rules for IRS-linked systems. Require routine updates and avoid shared credentials across users.

    • Assign clear roles within the organization: Identify the individuals responsible for preparing files, submitting forms, managing IRS feedback, and storing records.

    • Establish a year-round filing schedule: Spread tasks like data verification, platform testing, and IRS system updates across multiple months to avoid last-minute errors.

    • Print and retain submission records: Save digital or physical copies of confirmations, feedback reports, and system messages. Follow IRS retention guidelines for accessibility.

    Implementing these actions helps build a reliable filing structure that supports consistent compliance with IRS regulations. Organizations that plan, assign responsibility, and prioritize secure filing methods reduce risks across every tax year.

    Frequently Asked Questions

    When does the IRS require electronic filing for 1099s and W-2s?

    Electronic filing is required when a business or payroll provider files 10 or more returns for the same tax year. The IRS counts all information returns, including Forms 1099 and W-2, in this total. The 10-form threshold applies across form types and issuers, regardless of the number of recipients. Providers should track filing volume early to avoid missing the January electronic submission deadline or triggering penalties for using paper forms without authorization.

    What is the locked padlock icon seen on IRS platforms?

    The locked padlock icon indicates a secure, encrypted connection between the user and the IRS site. This symbol appears on authorized pages where sensitive taxpayer information is transmitted or accessed. Payroll companies should confirm the presence of this icon before entering login credentials or uploading returns. It assures that the IRS system protects the data processed through its FIRE or IRIS platforms.

    How can an organization outsource e-filing?

    Organizations may consider outsourcing if they lack internal expertise, need to file large volumes, or want help managing IRS formatting rules. Approved vendors offer secure systems, updated instructions, and technical support tailored to each IRS platform. Outsourcing can reduce the burden of manual reviews while maintaining filing accuracy. Select a vendor that provides access to confirmation records and permits internal review of returns before transmission.

    What if I need to mail paper returns instead?

    Mailing returns is permitted only if your business qualifies for a waiver from the electronic filing requirement. You must submit IRS Form 8508 to request approval in advance. Without a waiver, mailing returns may result in penalties. When paper filing is allowed, follow the latest IRS instructions, use the correct form layout, and confirm the mailing address on the IRS page for that tax year’s filing method.

    When should I begin preparing for the January deadline?

    Preparation should begin no later than early December. Review recipient data, validate IRS account credentials, and check for any system changes announced for the current tax year. Updates to the FIRE or IRIS platform may impact file layout or submission methods. Assign internal roles, confirm software access, and perform trial uploads if your system supports test transmissions before the January deadline approaches.

    What does the IRS site recommend for secure account setup?

    The IRS site advises using multi-factor authentication, strong passwords, and role-based access control. All users should be registered through the organization’s primary IRS account and granted specific permissions. Avoid shared credentials, and regularly update access rights when employees change roles. Use encrypted devices, verify the page before entering data, and monitor user activity to ensure compliance with security protocols required for FIRE and IRIS systems.

    Are there helpful resources or vendors I can contact?

    The IRS provides detailed guidance through Publication 1220 and its FIRE and IRIS support pages. These include system requirements, file formatting rules, and submission instructions. Approved vendors also publish helpful walkthroughs based on IRS specifications. Use the contact options listed on the IRS support site if you need clarification. Refer to IRS.gov for updated and accurate information on electronic filing requirements.