Do landlords need a TCC to file 1099s for rent payments? The answer depends on how much information you return to the IRS each year and how you submit it. A Transmitter Control Code (TCC) is the unique identification number the IRS assigns for filing information returns electronically. Understanding when this code is required helps landlords and property managers stay compliant and avoid penalties.

The IRS requires landlords to issue Form 1099-MISC when they pay $600 or more in rent to an individual or business during trade or property management. If you file 10 or more returns, you must file electronically rather than on paper. You may need to apply for a transmitter control code to use the IRS FIRE or IRIS intake systems.

This guide explains the key rules in plain language to see when a TCC is required, how to apply for one, and what happens if you don’t comply. You’ll also learn about penalties, hardship waivers, and common filing mistakes. Whether you manage a single rental property or run a larger company, these details will help you confidently prepare for tax season.

What is a Transmitter Control Code (TCC)?

A Transmitter Control Code (TCC) is a five-character alphanumeric identifier issued by the Internal Revenue Service. It is required when businesses or individuals must file information returns electronically. For landlords, this includes filing Form 1099-MISC for rent payments when they meet IRS thresholds. The transmitter control code serves as the IRS’s way of recognizing and authenticating who sends files through its electronic systems.

The primary purpose of the TCC is to ensure that electronic filings are secure, accurate, and traceable. Landlords, property managers, and companies cannot directly e-file required returns without a valid code. Instead, they would need to either qualify for a waiver or use a third-party service that already holds its own TCC.

Key Functions of a TCC

  • Identity verification

The TCC verifies the identity of the landlord, business, or company filing information returns electronically. This prevents unauthorized individuals from transmitting sensitive tax data.

  • File tracking

Each TCC allows the IRS to track submissions by transmitter. This ensures that every batch of information returned is linked to the correct filer, which helps resolve disputes or errors.

  • Compliance and audit support

By tying electronic submissions to a specific TCC, the IRS can accurately review, audit, or assess penalties. Landlords and property managers who must file 10 or more returns benefit from using the code to remain compliant.

The IRS provides details on how to apply for a TCC and when one is required. For the most current guidance, visit the official IRS website.

When Landlords Must File 1099-MISC Forms

The IRS requires landlords to issue Form 1099-MISC when making certain rent payments. This obligation is based on the amount paid, the type of recipient, and whether the costs are part of a business activity. Understanding these rules is essential for avoiding mistakes that could lead to penalties.

IRS $600 Rent Threshold

Landlords must file a 1099-MISC if they pay $600 or more in rent during the tax year. These payments must be connected to a trade or business, not personal property rentals. For example, a landlord renting out a vacation cabin for personal income would not file a form, but a property manager overseeing multiple units as part of a business would.

Who Requires a 1099-MISC?

  • Individuals

Any person receiving $600 or more rent from a landlord or property manager.

  • Partnerships

Entities that receive rent payments typically require a 1099-MISC.

  • Corporations

Most corporate landlords are exempt, but exceptions include payments to attorneys or medical corporations.

Important Exceptions for Property Managers and Agents

  • If a landlord pays rent through a property manager or agent, the landlord does not file a 1099-MISC. Instead, the agent or property manager is responsible for filing the form with the IRS.

  • This rule shifts the reporting duty away from individual landlords, simplifying the process when a professional management company is involved.

Practical Filing Scenarios

  • Direct landlord payments

If you personally pay rent to a property owner and the amount exceeds $600, you must file a 1099-MISC.

  • Payments through property managers

The manager files the form in this case, and the landlord does not.

  • Common mistakes to avoid

Landlords often fail to report payments made to unincorporated entities, assuming incorrectly that the rule only applies to individuals.

Landlords should review the IRS Instructions for Forms 1099-MISC and 1099-NEC for official filing criteria and examples.

The 10-Return Threshold and Electronic Filing Rules

The IRS requires landlords, property managers, and businesses to file information returns electronically once they reach a specific volume. This rule is commonly called the 10-return threshold. It applies to all information returns combined, not just Form 1099-MISC.

Explanation of the 10-Return Aggregate Rule

The rule requires electronic filing if you submit 10 or more information returns in a calendar year. The count is based on the total number of forms you file, regardless of type. For example, if you file six Forms 1099-MISC and four Forms 1099-NEC, you meet the threshold because the combined total is 10.

Which Forms Count Toward the Threshold

The following forms are included in the 10-return calculation:

  1. Forms 1099 (all variations, including 1099-MISC and 1099-NEC)

  2. Forms 1098 (mortgage interest statements)

  3. Forms W-2G (gambling winnings)

  4. Forms 3921 and 3922 (stock-related transfers)

  5. Forms 5498 (IRA contributions and distributions)

Paper Filing vs. Mandatory Electronic Filing

  • You may still use paper forms if you file fewer than 10 information returns.

  • If you file 10 or more returns, you must file electronically. This requires either:


    • Apply for a transmitter control code to use the IRS systems directly, or

    • Hiring a third-party provider that files on your behalf.

By understanding the 10-return rule, landlords and businesses can plan and avoid last-minute issues during filing season.

FIRE vs. IRIS: Which System Should You Use?

When filing information returns electronically, landlords and businesses must choose between two IRS systems: FIRE (Filing Information Returns Electronically) or IRIS (Information Returns Intake System). Each system has its transmitter control code and features, so understanding the differences is essential before applying.

Overview of the Two IRS Systems

  • FIRE System

It is a long-standing platform designed for bulk filing. Tax professionals, payroll providers, and companies with high filing volumes commonly use it.

  • IRIS System

A newer web-based portal intended for smaller filers. It provides fill-in forms and a more user-friendly experience.

Key Features of FIRE (Bulk Filing, Tax Professionals)

  • The FIRE system supports large batches of submissions, making it well-suited for high-volume filers such as property management companies and tax professionals.

  • It offers test environments that allow users to practice uploading files before submitting official information returns, reducing the risk of errors.

  • The system integrates with professional tax software, which helps businesses streamline the process of filing information returns electronically.

  • To access the FIRE platform, filers must obtain a dedicated FIRE-TCC issued by the IRS.

Key Features of IRIS (Web-Based, Small Filers)

  • The IRIS system works directly in a web browser and provides fill-in forms, which makes it straightforward for users without specialized software.

  • It is accessible to landlords and small businesses that file limited annual information returns.

  • The platform is easier for individuals or companies unfamiliar with technical filing processes, offering a simplified online experience.

  • Users must apply for and receive a separate IRIS-TCC from the IRS to file through IRIS.

Why TCCs Are System-Specific and Not Interchangeable

A transmitter control code is tied to the system for which it is issued. An IRIS-TCC cannot be used to log into FIRE, and a FIRE-TCC will not work in IRIS. You may have to apply for a second code if your needs change.

Choosing the Right System

  • Most suitable for small landlords

IRIS is usually more practical for those filing between 10 and 50 returns who want a straightforward, online solution.

  • Most suitable for property management companies or CPAs

FIRE is more effective for managing hundreds of returns, integrating software, and filing for multiple clients.

Step-by-Step Guide to Applying for a TCC

Applying for a Transmitter Control Code (TCC) requires preparation, documentation, and awareness of deadlines. The process differs slightly depending on whether you need an IRIS TCC or a FIRE TCC, but both require careful attention to detail.

Preparation and Requirements

Before applying, gather the following information:

  1. An Employer Identification Number (EIN)is mandatory for all applications.

  2. A Social Security Number (SSN) or Individual Taxpayer Identification Number (ITIN) is required for identity verification.

  3. Complete business details, including mailing address, phone number, and contact information.

  4. Information about authorized users must be listed and verified for each person accessing the system.

Applying for an IRIS TCC

  1. Create an IRS account through ID.me. 

Each authorized user must complete the ID.me verification process, which includes government-issued identification and multi-factor authentication.

  1. Log in to the IRS portal. 

Access the IRIS TCC application page using your verified ID.me credentials.

  1. Submit your application. 

Enter your business information, EIN, and intended filing volume, then add all authorized users.

  1. Receive confirmation. 

The IRS typically processes applications within 45 days, though delays can occur during peak filing periods.

Applying for a FIRE TCC

  1. Access the FIRE application. 

Navigate to the IRS site for the Information Returns (IR) Application for TCC.

  1. Choose your role. 

Indicate whether you are a transmitter filing for multiple clients or an issuer filing only for your business.

  1. Provide business and identity details. 

Submit your EIN, SSN, or ITIN, and accurate contact information.

  1. Complete verification. 

To avoid rejections, ensure that all details match IRS records.

  1. Await processing. 

Allow at least 45 days for the IRS to approve and issue your FIRE-TCC.

By following these steps, landlords, property managers, and businesses can obtain the appropriate transmitter control code in time for filing season. Applying early is critical because waiting too long may result in processing delays that prevent you from meeting deadlines.

Penalties and Compliance Risks

Failing to follow the IRS rules for filing information returns electronically can lead to steep penalties. Landlords and businesses that miss deadlines, file with the wrong system, or fail to apply for a transmitter control code may face increased fines over time.

Penalty Structure for Electronic Filing

  • $50 per return if the error is corrected within 30 days of the due date.

  • $100 per return if corrected between 31 days and August 1.

  • $280 per return if filed after August 1 or not filed at all.

Annual maximums apply, but the costs can still be significant, especially for companies handling large volumes of forms. Even a single employee tasked with compliance must pay close attention to details when filing information returns electronically.

Common Compliance Errors

  • Filing paper forms when electronic filing is required.

  • The submission was made through the incorrect IRS system (using a FIRE TCC instead of an IRIS TCC).

  • Allowing a TCC to expire after three years of inactivity is not acceptable.

  • Overlooking the need to include a cover letter for specific FIRE applications.

Practical Tips for Avoiding Penalties

  • Check deadlines early. Start preparing well before the November 1 cutoff for TCC applications.

  • Walk through the process in advance.  Use IRS test systems to verify file formats and submission methods.

  • Keep records secure. IRS portals display a locked padlock icon to remind you that your session is encrypted, but you should still safeguard your login details.

  • Review your data. Ensure that names, addresses, and bank account information align precisely with IRS records.

Staying Informed

IRS rules can change yearly, and requirements may vary by state. Always make time for careful reading of official IRS instructions and guidance. If you have questions, consider contacting a professional or reviewing the IRS website for updates. 

To maintain accuracy and trust, note when your compliance material was last reviewed or updated. This simple practice reassures readers that the information they rely on is current. For reference, add a footer such as “Page last reviewed: [month year]” at the end of your materials.

Waivers and Exceptions: Form 8508

Landlords and businesses that cannot meet the IRS requirements for electronic filing may qualify for a hardship waiver. Form 8508 allows you to request permission to file on paper instead of using IRS systems. This option is limited and must be supported by strong documentation.

When a Waiver May Apply for E-File Rules

If electronic filing creates significant difficulty, the IRS may approve a waiver. Valid reasons can include the high costs of electronic filing software, lack of reliable internet access, or other technological barriers. Financial hardship must be well-documented to be considered.

Filing Information Returns Electronically and Exceptions

Taxpayers must file information returns electronically if they submit 10 or more returns. However, those with approved waivers may use paper filings. It is important to remember that approval is not automatic, and landlords should not assume a waiver will be granted.

Supporting Documentation for Form 8508

When applying for a waiver, you must provide:

  • Two cost estimates from vendors or software providers to demonstrate the financial burden.

  • A written explanation showing why filing information returns electronically is not possible.

  • Any supporting records that show technical limitations or lack of access to required systems should be included.

Filing Information Returns and Deadlines

Form 8508 must be submitted 45 days before your information returns are due. Missing this deadline will likely result in denial, and you may face penalties for failing to comply. Remember that the waiver applies only to the year it is granted, and a new request must be submitted for future filing seasons.

What If You Have 10 or More Returns?

If you must file 10 or more returns and do not have an approved waiver, you must submit information returns electronically. Failure to do so may lead to penalties and IRS compliance issues.

Real-World Scenarios and Examples

Understanding how the rules apply in real life helps landlords and property managers see whether they need a transmitter control code. Each subject in the following examples shows how filing obligations change depending on the number of returns and the role of the filer.

  • Small Landlord Under the Threshold

A landlord with eight tenants issues eight Forms 1099-MISC. Since the total is less than 10, the landlord can file it on paper and does not need a TCC.

  • Property Management Company Over the Threshold

A management company pays owners and contractors and files 20 combined forms. Because the total exceeds 10, the company must file electronically and obtain a TCC.

  • CPA Firm Filing for Clients

A CPA firm prepares hundreds of information returns for multiple landlords. The firm is treated as a transmitter and must apply for a FIRE-TCC to remain compliant.

  • Nonprofit with Rental Income

A nonprofit leases space and issues 12 Forms 1099-MISC. Even though it is tax-exempt, the nonprofit meets the 10-return threshold and must file electronically.

  • Gig Economy Platform

A property rental app issues thousands of 1099-K and 1099-MISC forms. This volume requires a FIRE-TCC and integrated filing software to manage compliance effectively.

These examples illustrate how filing requirements depend on filing volume and business structure, not just the type of property or organization.

Troubleshooting Common TCC Issues

Even with careful preparation, landlords and businesses may encounter problems when applying for or using a transmitter control code. Knowing the most frequent issues—and how to resolve them—can prevent delays and penalties.

Application Rejections

  • EIN mismatch

The application will be rejected if the Employer Identification Number does not match IRS records. Verify your EIN and business name with IRS Entity records before resubmitting to fix this.

  • ID.me authentication failures

Identity verification can fail for IRIS TCC applications if personal details do not match government records. Completing the verification carefully and contacting ID.me support often resolves the issue.

System Access Problems

  • FIRE login issues

Filers may be denied access if they use an incorrect TCC, an expired code, or outdated login details. Always confirm your FIRE-TCC is current and test your login credentials in the FIRE test system.

  • IRIS portal errors

Access may be denied if authorized users are not appropriately linked to the account. Each user must have an active ID.me profile connected to the business application.

Filing Submission Errors

  • File format rejections

Submissions may fail if the file does not meet Publication 1220 specifications. Using approved e-file software and testing files before the deadline reduces this risk.

  • Duplicate submissions

Sending the same file twice can create compliance issues. To avoid this, maintain detailed records of each submission, including timestamps and confirmation notices.

By checking these common problem areas in advance, landlords and property managers can start filing more confidently and reduce the likelihood of last-minute issues.

Maintaining and Renewing Your TCC

Landlords and businesses must ensure that a transmitter control code remains active after receiving it. The IRS has specific requirements for TCC maintenance, and failure to follow them may cause the code to expire.

The Three-Year Expiration Rule

A TCC will expire if it is not used for three consecutive years. Once expired, it cannot be reactivated, and the filer must submit a new application. To prevent this, transmitters should file at least one return every three years, even if the filing volume is low.

Updating Business and User Information

The IRS requires that business and contact information remain current. If your company changes its name, address, or authorized personnel, you must update these details with the IRS. This ensures that notices and confirmations are sent to the right person.

Best Practices for Keeping Your TCC Active

  • Submit a test file annually, even if you do not expect to file many returns.

  • Monitor IRS communications and respond promptly to any requests for updates.

  • Keep accurate records of all filings, confirmations, and correspondence related to your TCC.

  • Regularly review authorized user access and remove anyone who no longer represents your business.

Maintaining a valid TCC saves time and effort during tax season, ensuring you do not face last-minute delays caused by expired or outdated credentials.

Frequently Asked Questions (FAQs)

Do I need a TCC if I only file a few 1099s?

No, if you file fewer than 10 information returns in total for the year, you can submit paper forms without applying for a TCC. The IRS requires electronic filing once your returns reach 10 or more. At that point, you must apply for a TCC or use a third-party provider with its code.

Can one TCC be used for both FIRE and IRIS systems?

No, TCCs are system-specific, which means the IRS issues separate codes for FIRE and IRIS. A FIRE-TCC only works in the FIRE system, and an IRIS-TCC only works in the IRIS system. If your filing needs change, you may apply for a second code to comply with electronic filing requirements.

What happens if I use a third-party service to file my 1099s?

If you use a third-party provider, you do not need your own TCC. The service files are under their transmitter control code, and the submission process is handled. However, you should always request filing confirmations for your records. This ensures your information returns are appropriately filed and helps protect you in case of errors, disputes, or IRS compliance checks.

How long does IRS approval for a TCC take?

Approval typically takes at least 45 days, though processing may be slower during peak filing seasons. Because of this timeline, the IRS recommends applying before your filings are due on November 1 of the year. Applying early allows time to resolve identity verification issues or application errors without delaying your ability to file information returns electronically.

What if my TCC expires after three years of non-use?

Once a TCC has expired, it cannot be reactivated. You will need to submit a new application and wait for IRS approval. Use your code at least once every three years to prevent expiration, even if filing only test submissions. By staying active, you can avoid the application process from delaying you during tax season.