The Internal Revenue Service has updated its electronic filing requirements, lowering the threshold for filing information returns electronically from 250 to just 10 per tax year. This change impacts thousands of employers, sole proprietors, and legal businesses that once mailed paper forms, requiring them to e-file information returns through approved systems such as the IRS FIRE system and the Information Returns Intake System (IRIS).

A transmitter control code, often called a TCC code, is required to electronically file information returns with the Internal Revenue Service and Social Security Administration. Whether using a FIRE TCC for a fire system account or an IRIS TCC for the intake system, your company must provide its legal business name, employer identification number, and responsible official details. Without this authorization, forms like those reporting income tax withheld cannot be filed electronically, exposing employers to penalties.

This guide provides step-by-step instructions to help employers, tax professionals, and third-party transmitters complete a new IR application, add responsible officials or authorized users, and submit required information on schedule. You will learn how to log in, verify account details, manage CSV file or CSV template uploads, review application summaries, and click submit to reach completed status. With practical strategies and deadlines, this article ensures your own company is ready for electronic filing and compliance with IRS requirements.

What is a TCC and Why It Matters

Definition of a TCC

A transmitter control code is a unique five-digit number that the IRS gives you to approve electronic filing of your information returns. It serves as your digital authorization, allowing your business to transmit returns securely to federal agencies. The IRS uses this code to ensure your data stays secure and to keep track of all electronic submissions, making the process trustworthy and transparent.

Why Businesses and Tax Professionals Need a TCC

The IRS created TCC requirements as part of comprehensive security measures protecting sensitive taxpayer data from unauthorized access. Your business must secure the correct TCC based on which filing system you choose and how many returns you submit annually. Tax professionals handling multiple client accounts need transmitter authorization, while individual businesses typically qualify for issuer status covering only their own filings.

  • Security protection: TCCs prevent unauthorized individuals from accessing IRS electronic filing systems. This safeguard protects taxpayer information and maintains system reliability.

  • Filing permission: Electronic return submission becomes impossible without a valid TCC regardless of the choice of filing system. The code verifies that your business meets all IRS requirements for electronic filing participation.

  • System matching: Each IRS filing system requires a unique TCC, making proper selection essential for success. Your TCC type must align with your chosen filing system and anticipated submission volume.

The 2025 E-Filing Mandate

IRS Electronic Filing Threshold Update

The IRS cut the number of information returns that must be filed electronically from 250 to 10 each year, starting with the 2023 tax year. This change affects far more businesses than previous regulations required to convert to electronic systems. The count includes all the tax forms your business has to file, not just W-2 forms.

  • Total return calculation: The 10-return limit encompasses all information returns combined, including Forms 1099, W-2, and other mandatory filings. Your business must total every information return filed during the entire tax year.

  • Complete conversion requirement: Reaching the threshold means all information returns must go electronic, not just the forms that pushed your count beyond 10. This comprehensive approach demands full system conversion for qualifying businesses.

Examples of Filing Requirements for Different Entities

Different types of businesses show how the 10-return limit affects them and their responsibilities to follow the rules. These examples show how companies can figure out exactly what forms they need to fill out.

  • Service company case: A cleaning business employing eight workers plus three independent contractors files 11 combined returns (8 W-2s and 3 1099-NECs). Electronic filing becomes mandatory for every return due to exceeding the limit.

  • Professional firm situation: A tax preparation office handling multiple client returns surpasses the 10-return threshold across numerous form types. Electronic filing applies to all client submissions throughout the entire tax year.

  • Charitable organization example: A nonprofit filing 12 employee W-2s plus five vendor 1099-MISC forms reaches 17 total returns. The organization must switch to electronic filing for all information return submissions.

Understanding IRS Filing Systems: FIRE vs. IRIS

FIRE System Overview

The FIRE system is an online platform for filing information returns electronically. It is especially helpful for large organizations and software developers who need robust processing features. While it handles most types of returns, the Social Security Administration handles W-2 forms directly. Using FIRE requires some technical knowledge and is designed for users managing a high volume of returns.

  • Unlimited processing: The FIRE system handles massive return volumes without restrictions, making it perfect for large businesses and processing services. Users submit thousands of returns through efficient batch formatting procedures.

  • Technical demands: Success requires specific file formatting knowledge and technical skills according to IRS specifications. Users must generate correctly formatted files following detailed guidelines in Publication 1220.

IRIS System Overview

The Information Returns Intake System (IRIS) is a simple option for small to medium-sized businesses that need to process up to 100 returns at a time. This web-based platform lets you enter data by hand or upload CSV files to make processing easier. System access costs nothing and requires minimal technical knowledge.

  • Easy navigation: The IRIS system features simple interfaces allowing manual data input or CSV template uploads. This design removes technical obstacles for small business owners and their employees.

  • Volume restrictions: Despite being easier to operate, the system caps submissions at 100 returns per batch and processes more slowly than FIRE. Higher-volume businesses may require multiple submission sessions to complete filing.

Key Differences Between FIRE and IRIS

  • Volume Capacity
    • FIRE System: Unlimited returns
    • IRIS System: Up to 100 returns per batch
  • Technical Difficulty
    • FIRE System: High — requires file formatting knowledge
    • IRIS System: Low — simple, web-based interface
  • Cost
    • FIRE System: Free
    • IRIS System: Free
  • User Type
    • FIRE System: Best for large-volume filers and developers
    • IRIS System: Best for small to medium-sized businesses
  • File Upload
    • FIRE System: Accepts formatted files only
    • IRIS System: Accepts CSV template uploads or manual entry
  • Who Must E-File W-2 Forms in 2025

    IRS Thresholds and Filing Obligations

    Businesses that file 10 or more information returns in a calendar year must do so electronically. This requirement applies to all businesses, no matter how big, what type of business they are, or what industry they are in. The calculation takes into account all the information return categories that your business entity has filed.

    • Broad application: The 10-return limit affects all business entities, including corporations, partnerships, LLCs, and sole proprietorships. Business size or annual revenue does not create exemptions from this requirement.

    • Annual counting method: The IRS tallies returns filed during the calendar year rather than the tax year being reported. Your business must monitor annual filing volume to determine compliance obligations accurately.

    Real-World Filing Scenarios

    Different business models encounter varying combinations of information returns that may trigger electronic filing requirements. These situations illustrate how the threshold applies across diverse industries and operational structures.

    • Retail operation: A store with six employees and five contractors files 11 total returns (6 W-2s plus 5 1099-NECs). Once the threshold is exceeded, electronic filing becomes required for all returns.

    • Healthcare practice: A medical office filing 15 employee W-2s automatically surpasses the threshold requirement. The practice must electronically file all information returns, including any future 1099 forms issued.

    Step-by-Step Guide to Applying for a TCC

    Step 1: Applying for a TCC for W-2 Filing through SSA

    W-2 forms go directly to the Social Security Administration through their Business Services Online system rather than the IRS system. Employers must register separately for SSA electronic filing services, independent of IRS system registration. The SSA promotes electronic filing for all employers regardless of volume to enhance accuracy and processing efficiency.

    Step 2: Applying for an IRIS TCC

    The IRIS TCC application requires completing the IR application through the IRS website with proper verification and complete business details. During the process, you must provide your employer identification number, legal business name, and designated responsible official information. Every authorized user needs their own ID.me account for system access authentication.

    • Documentation needs: Submit complete business entity details, including legal business name, EIN, and physical location address. Designate a responsible official with binding authority and include all authorized system users.

    • Timeline considerations: Applications submitted by November 1st receive processing priority before the filing season begins. The IRS allows up to 45 days for application review and TCC approval completion.

    Step 3: Applying for a FIRE TCC

    The FIRE system demands a separate TCC application through the FIRE portal using documentation and verification requirements similar to those of IRIS applications. Businesses planning to use both systems must apply for distinct TCCs since codes cannot be transferred between systems. Application processing follows identical timelines and ID.me authentication requirements as IRIS submissions.

    Critical Deadlines and Filing Timeline

    TCC Application Deadlines

    The IRS strongly recommends that the TCC application be submitted by November 1st to guarantee processing completion before the filing season commences. Applications received after this date may not achieve approval in time for mandatory filing deadlines. Processing periods can extend up to 45 days from the initial submission date.

    • November deadline importance: This recommendation provides adequate processing time before January filing requirements take effect. Late applications risk complete filing season exclusion.

    • Processing extensions: Peak application volumes may stretch processing times beyond the standard 45-day period. Early submission creates buffer time for application problems or required corrections.

    W-2 Filing Deadlines for 2025

    W-2 forms require submission to the Social Security Administration and employee distribution by specific due dates each year. The electronic filing deadline is February 2, 2026, for the 2025 tax year W-2 forms. Paper filing is allowed only if your business falls below the 10-return threshold, but the due date remains unchanged.

    • Employee distribution: Employers must deliver W-2 forms to employees by January 31, 2026, regardless of the chosen filing method. This deadline occurs several days before the SSA filing requirement.

    • Extension rarity: According to IRS regulations, W-2 filing extensions are approved only under exceptional circumstances. Businesses should establish filing schedules well ahead of the scheduled date.

    ID.me Requirements and Common Issues

    What Documents and Setup Are Needed

    ID.me verification demands government-issued photo identification, a phone number for SMS confirmation, and an email address for account establishment. The verification process may include facial recognition technology matching photo identification documents. Each authorized user must complete individual verification processes independently.

    • Identification standards: A valid driver's license, passport, or state-issued ID card with clear, readable photographs is required. The documents must remain current and match the user's exact legal name.

    • Verification steps: Users complete identity confirmation through photo uploads, SMS verification, and potentially video discussions with ID.me representatives. The process usually finishes within minutes, but may extend during busy periods.

    Common ID.me Verification Problems

    Authentication delays frequently occur during peak filing seasons when verification requests increase dramatically. Document quality problems often cause verification failures requiring resubmission with improved photographs. Multiple user verification needs can create processing bottlenecks in TCC application workflows.

    • Technology challenges: Browser compatibility problems and internet connection issues can disrupt the verification process. Users should attempt verification with updated browsers and reliable internet access.

    • Photo standards: Blurry images, lighting glare, or incomplete document photos trigger automatic verification rejection. Users must supply clear, well-illuminated photographs displaying the complete document.

    Penalties and Compliance Risks

    Late Filing Penalties

    The IRS enforces graduated penalty structures based on filing delay length, with amounts escalating significantly over time. Small businesses averaging $5 million or less in annual gross receipts qualify for reduced penalty amounts. Penalties accumulate per return, creating substantial exposure for high-volume filers.

    • Early penalty tier: Returns filed within 30 days past the due date trigger $310 per return penalties, with a maximum annual assessment of $1,240,000. Small business relief reduces this maximum to roughly one-third of standard amounts.

    • Severe delay penalties: Returns filed beyond 30 days late but before August 1st face $620 per return assessments. Filing after August 1st activates the highest penalty level of $1,550 per return.

    Penalties for Failing to File Electronically

    Businesses required to file electronically that submit paper returns encounter identical penalty structures as late filing violations. The IRS considers paper filing when electronic submission is mandated as a complete failure to file. These penalties compound per return, generating substantial financial consequences for non-compliant operations.

    • Mandate violation consequences: Paper filing when electronic submission is required triggers immediate penalty assessment procedures. The IRS provides no grace periods for businesses unaware of electronic filing obligations.

    • Waiver limitations: Only businesses with approved hardship waivers using Form 8508 may submit paper returns when electronic filing is mandated. Religious objections and technical impossibility constitute the primary waiver qualification ground.

    Troubleshooting and Compliance Management

    Common TCC Application Issues

    Application rejections typically stem from incomplete business information, invalid employer identification numbers, or authentication system failures. Verifying all required contacts maintain valid ID.me accounts before submission prevents typical processing delays. Responsible official details must precisely match business registration records.

    • Data precision: Confirm EIN accuracy and verify legal business name alignment with official business registration documentation. Information discrepancies between applications and IRS records trigger automatic rejections.

    • Contact specifications: Each TCC application must include at least two contacts and a maximum of 250 authorized users. Each contact must finish ID.me verification before the application is submitted.

    Common Filing System Errors

    Electronic submission rejections often result from file format violations, invalid taxpayer identification numbers, or software compatibility problems. Testing systems with limited batches before complete submission helps identify technical issues early. Current software versions ensure compatibility with present tax year specifications.

    Deadline Management Best Practices

    Calendar reminders for TCC applications, filing deadlines, and system testing prevent last-minute compliance emergencies. Backup filing plans address potential system failures or technical complications. Regular compliance assessments help identify evolving requirements affecting filing responsibilities.

    Practical Examples and Case Studies

    Small Business Example

    A neighborhood restaurant employing eight workers and three contractors files 11 total information returns, activating mandatory electronic filing requirements. The business must secure a TCC and transition all filing processes to electronic submission methods. This conversion requires staff training and system preparation before the filing deadlines approach.

    CPA Firm Example

    A tax preparation firm filing returns for numerous clients easily surpasses the 10-return threshold across various information return categories. The firm needs transmitter TCC authorization to file client returns and must develop comprehensive electronic filing procedures. Client permission and data protection become essential compliance elements.

    Nonprofit or Gig Economy Example

    A charitable foundation filing 15 employee W-2 forms plus vendor 1099-MISC forms must establish electronic filing systems. Gig economy platforms processing thousands of 1099-K and 1099-NEC returns need sophisticated FIRE system capabilities. These organizations require early TCC applications and comprehensive system testing procedures.

    Compliance Checklist for E-Filing W-2 Forms

    Before Applying for a TCC

    • Secure a valid EIN: Verify your employer identification number remains current and matches all business registration documentation.

    • Establish ID.me accounts: Each authorized user must create an individual ID.me verification before the TCC application submission occurs.

    • Compile business details: Gather complete legal business name, address, and responsible official information for application accuracy.

    • Select system requirements: Choose between FIRE and IRIS systems based on filing volume and technical capability assessments.

    During the Application Process

    • Fill required sections: Supply accurate information in all mandatory application areas to prevent processing delays.

    • Name of responsible official: Choose an individual with proper business authority and verify their information matches business records precisely.

    • Include authorized contacts: Add at least two contacts with a maximum of 250 users, confirming each completed ID.me verification.

    • Verify before submission: Check all information accuracy and completeness before clicking submit to prevent rejection.

    After Receiving a TCC

    • Confirm system access: Verify login credentials and system functionality well before filing deadlines arrive.

    • Check file formats: Ensure software produces properly formatted files meeting IRS specifications in Publication 1220.

    • Develop backup strategies: Create alternative filing methods for system outages or technical difficulties.

    • Schedule reminders: Establish annual reminders for TCC renewals, filing deadlines, and compliance assessments.

    Annual Filing and Recordkeeping Steps

    • Track filing volume: Monitor information return quantities throughout the year to maintain electronic filing requirement compliance.

    • Save confirmation records: Retain all electronic filing confirmations and error reports for IRS audit documentation purposes.

    • Update system software: Install current tax year updates and verify compatibility with IRS systems before filing seasons begin.

    • Monitor penalty notices: Review IRS transcripts and correspondence for penalty assessments requiring response or appeal action.

    Frequently Asked Questions

    What is the difference between a FIRE TCC and an IRIS TCC?

    The Internal Revenue Service issues a FIRE TCC for the FIRE system account, which allows businesses and third-party transmitters to electronically file information returns in large volumes. In contrast, an IRIS TCC is designed for the Information Returns Intake System, allowing employers or tax professionals to e-file information returns using a CSV file format with simplified access.

    Can W-2 forms be filed through the IRIS system?

    No. W-2 forms must be filed directly with the Social Security Administration using Business Services Online, not the IRIS system. The intake system managed by the IRS processes only information returns like Form 1099. Employers should confirm their legal business name, employer identification number, and required information when using the correct system to file electronically.

    What happens if I miss the November 1st TCC application deadline?

    If you submit an IR application after the November 1st scheduled date, your application summary may not reach completed status before the tax year filing season begins. Without a valid TCC code, you cannot electronically file information returns. The IRS requires timely submissions, and missing the due date could trigger penalties, rejected files, or time request denials.

    Do I need a TCC if I use a payroll or CPA service?

    If your company uses a payroll provider or CPA, they should already have a transmitter control code to file information returns electronically. However, the IRS encourages transmitters to provide confirmation records. Employers may still apply for a TCC FIRE or IRIS account for direct control, adding responsible officials and authorized users to oversee the filing process.

    Can nonprofits or small businesses request penalty relief?

    Yes. Nonprofits and small businesses that fail to file electronically may request penalty relief under Internal Revenue Code Section 6724. For example, a sole proprietor or legal business with gross receipts under $5 million qualifies for reduced penalty limits. Organizations must submit a written request showing reasonable cause, such as technical access issues or authorized delegate errors, to succeed.

    How long does a TCC remain valid once issued?

    A TCC code remains active as long as the company files information returns on time and complies with IRS requirements. The Internal Revenue Service may revoke accounts that fail to sign in, add responsible officials, or electronically file for multiple tax years. FIRE users and IRIS users must maintain a completed status to keep their accounts valid.