Nonprofit organizations that issue contractor payments, process educational forms, or report charitable contributions must file information returns with the IRS. Electronic submission becomes mandatory when those filings reach ten or more in a calendar year. To proceed, your organization must obtain a Transmitter Control Code (TCC) to access IRS-approved e-filing systems.
A TCC is a five-character identifier the IRS assigns to the legal business entity responsible for filing. It allows nonprofits to submit forms such as 1099-NEC, 1098, or 1042-S through secure electronic portals. Whether your organization is a sole proprietorship, partnership, or tax-exempt corporation, the IRS requires separate registration and validation for each entity. This process includes verifying responsible officials, assigning authorized delegates, and preparing your information in accepted formats.
This guide provides a complete overview of the TCC process for nonprofits. It explains how to choose between the FIRE and IRIS systems, complete your application, submit compliant files, and maintain ongoing access. This article outlines the complete process for nonprofits new to electronic filing in clear, accessible terms, each step in clear, practical terms—without requiring prior experience or technical knowledge.
A Transmitter Control Code (TCC) is a five-character identifier issued by the Internal Revenue Service (IRS) that authorizes an organization to file returns electronically. For electronic nonprofits, the TCC is an official access credential that links the filing organization’s account to IRS systems to transmit required documents securely.
Assigned to a specific employer identification number (EIN), the code is essential for organizations managing tax-reportable transactions, such as payments to contractors, tuition-related disbursements, or vehicle donation records. The TCC is mandatory when submitting ten or more information returns during a calendar year.
Depending on the type of form they submit, nonprofits can use the FIRE system or the IRIS portal. The code facilitates submission, identifies the filer, verifies authorized users, and ensures returns are correctly attributed to the legal business name on file with the IRS.
Understanding the purpose and scope of the TCC helps prevent misfiling and ensures the correct attribution of each return. It also allows your nonprofit to comply with IRS regulations across multiple reporting requirements, including those related to state and federal programs.
Organizations required to transmit returns through the FIRE system must apply using the official FIRE system for information returns, which supports a broad range of information return forms. Selecting the correct system and securing a valid TCC are foundational steps that affect the entire electronic filing process. They impact how forms are submitted, compliance is evaluated, and the IRS handles future transmissions.
Nonprofit organizations are subject to mandatory electronic filing when they submit ten or more information returns during a calendar year. This rule, introduced under Treasury Decision 9972, significantly expanded the scope of mandatory e-filing for tax year 2023 and beyond. Unlike the previous threshold of 250 returns, the revised standard requires many smaller organizations to comply with digital submission rules. Understanding how the IRS counts these returns is critical for compliance.
The 10-return rule applies at the entity level and includes all organization filing systems, including IRIS, FIRE, AIR, and SSA platforms. The count reflects the total number of returns transmitted under the same EIN, regardless of return type or IRS platform used. Even if the organization delegates filings to a payroll provider or software vendor, the obligation remains with the nonprofit.
Failing to file electronically when required may lead to penalties under Internal Revenue Code Section 6721. Organizations should conduct an annual return count and plan to ensure compliance. When filing obligations exceed the threshold, the next step involves securing the proper TCC, understanding formatting requirements, and selecting the appropriate IRS system for submission.
The IRS Information Returns Intake System (IRIS) provides a secure online platform for organizations required to file information returns electronically. Nonprofits applying for a Transmitter Control Code (TCC) through IRIS must complete a structured application process that verifies organizational details, responsible personnel, and intended filing activity.
This application is essential for ensuring accurate return attribution and system access. The IRIS portal supports the 1099 series and is designed to streamline the setup process for small and mid-sized organizations.
Before beginning the application, your nonprofit must prepare the following:
Every user accessing the IRIS system must pass identity verification and be assigned a specific role:
According to the IRS, organizations may complete the entire process online through the IRIS TCC Application portal, which offers secure access, identity verification, and application tracking. Nonprofits should review all application entries before submission to avoid processing delays. Once submitted, the application status can be monitored directly within the portal. A valid TCC will be assigned after the organization is approved to file the electronic information return.
Nonprofit organizations must carefully evaluate which IRS system aligns best with their electronic filing obligations. The two primary platforms, the Information Returns Intake System (IRIS) and the Filing Information Returns Electronically (FIRE) system, provide different features, filing capabilities, and technical requirements. Choosing the appropriate system is essential for accurate reporting and timely submission of information returns.
IRIS is designed for small—to mid-sized organizations, while FIRE accommodates broader form support, which may better suit more complex or higher-volume filing needs.
Both systems require a valid Transmitter Control Code, but are not interchangeable. Organizations filing through IRIS cannot use the same TCC for FIRE and vice versa. Before initiating the application, nonprofits should identify the forms they plan to file, review the technical infrastructure required, and evaluate the support available for their chosen method.
Selecting the right system ensures compliance with IRS mandates while aligning with the organization's size and capacity. Understanding the operational distinctions between these systems remains essential as electronic filing becomes more standardized.
Every nonprofit applying for a Transmitter Control Code (TCC) through the IRS must designate at least two Responsible Officials, except in cases involving sole proprietorships or single-member entities. These individuals serve as the organization's official representatives within IRS electronic systems.
Their roles include signing applications, overseeing return submissions, and controlling access credentials and system activity. Responsible Officials play a vital part in safeguarding the integrity of the organization’s tax reporting.
A Responsible Official must have significant authority over the organization’s operations. This includes executive directors, financial officers, or others authorized to act on behalf of the entity. Each designated individual must provide personal identification details, including legal name, Social Security number, date of birth, and current contact information.
These personal details are required for identity verification and secure system access. The IRS requires at least two Responsible Officials to help ensure continuity of oversight and accountability within the organization.
Before an application can be submitted, all Responsible Officials must verify their identities through an IRS-approved method. The current process includes validating information through third-party services and uploading supporting documentation.
This step is critical to prevent unauthorized access and to confirm that only qualified individuals manage sensitive tax data. Once verified, Responsible Officials receive unique credentials and a Personal Identification Number (PIN) to sign electronic applications and filings.
Establishing accurate roles within the TCC application helps preserve filing integrity and aligns with IRS expectations for secure e-filing practices. Nonprofits should carefully select qualified and available individuals to manage system access throughout the year.
In the event of leadership changes or staffing transitions, organizations must promptly update Responsible Official information to maintain uninterrupted access to the electronic filing platforms. Proper role management supports long-term compliance and minimizes disruptions during peak filing periods.
The Filing Information Returns Electronically (FIRE) system is an IRS platform that transmits a wide range of information returns extending beyond the Form 1099 series. Nonprofits may require access to the FIRE system if they file forms that are not supported under the IRIS portal or work with third-party processors managing multiple return types. A separate TCC is required for FIRE use, and the application process differs slightly from IRIS registration.
Selecting the appropriate system depends on the types of forms being filed and the organization's technical capacity. While IRIS suits smaller-scale submissions, FIRE accommodates a broader range of return types. Understanding the scope and function of each system ensures that your nonprofit aligns with IRS filing protocols while maintaining control over its compliance activities.
Nonprofit organizations that transmit information returns through the IRS FIRE or IRIS systems must ensure their data files meet strict formatting standards. When correctly structured, CSV files allow for the bulk upload of returns, reducing manual entry and minimizing submission errors. Proper file preparation also helps prevent processing delays and file rejections that could lead to compliance issues.
Before submitting a CSV file, the organization should review all formatting instructions published by the IRS. To be accepted by the receiving system, each return must follow a specific order of fields and character limits. The file name must also comply with naming conventions to ensure compatibility with the selected IRS platform.
IRS Publication 1220 provides the complete formatting guidance for FIRE-compatible CSV files, detailing technical specifications required for bulk electronic filing. Reviewing these instructions thoroughly before preparing the file helps reduce avoidable errors and ensures that submissions meet IRS standards. After uploading, organizations should retain transmitted files securely to support audits and allow future corrections if needed.
Nonprofits that fail to meet IRS e-filing requirements or mishandle their Transmitter Control Code (TCC) responsibilities may face significant financial penalties. These consequences apply to late filings, incorrect formats, missing recipient information, or failing to use electronic submission when required. Penalties vary based on the timing of the correction and the organization's size, but all entities are expected to maintain accuracy and timeliness in their information return reporting.
Organizations not following the required procedures may be penalized under Internal Revenue Code Section 6721. The IRS imposes fines per return, with higher rates for extended delays or intentional disregard. Organizations that use the wrong system or omit key identifiers, such as the TIN or form type, may also incur penalties.
Although penalty relief is available in limited situations, the IRS requires organizations to demonstrate that the failure was due to circumstances beyond their control. Supporting documentation must show that the issue was not due to negligence and that corrective measures were implemented promptly. Maintaining accurate submission records, timely filing schedules, and up-to-date TCC access helps nonprofits remain compliant while protecting limited financial resources.
Nonprofit organizations navigating the TCC application process or filing information returns often encounter preventable errors that result in rejected submissions or compliance issues. These mistakes usually stem from procedural oversights, incomplete records, or a misunderstanding of IRS system requirements. Identifying these risks early in the process helps ensure the organization maintains its eligibility to file and avoids delays in processing.
One of the most common issues is submitting an incomplete or inconsistent application. Errors may include mismatches between the legal business name and IRS records, missing responsible official information, or incorrect entry of the organization’s employer identification number. These issues delay approval and may prevent timely registration with the IRS e-filing system. The IRIS or FIRE application must be carefully reviewed for accuracy before submission.
Verification failures also contribute to many delays. Responsible officials must complete identity verification and provide supporting documentation that matches exactly across systems. Discrepancies between personal data, such as name spellings or dates of birth, and records held by the IRS or identity verification vendors may result in application rejection. The process becomes significantly slower when nonprofits assign this responsibility to individuals without confirming their eligibility or documentation readiness.
Technical mistakes during filing are also widespread. Many organizations attempt to upload files without validating CSV structure or matching form specifications, leading to rejected transmissions or misattributed data. Filing under the wrong EIN, uploading an unsupported form type, or submitting after system deadlines can all trigger penalties or noncompliance flags. Developing a review process and assigning qualified personnel for system interactions reduces the likelihood of these issues.
To ensure accuracy and compliance, nonprofits should develop internal checklists, test files where possible, and confirm all system access before peak filing periods. Addressing these common mistakes in advance improves efficiency and helps maintain a clear compliance record across filing seasons.
Monitor user access consistently: Nonprofits should regularly check who has system access and confirm that only approved personnel, such as responsible officials and authorized delegates, can log into the IRS filing portals. This helps prevent errors linked to unauthorized access or outdated user information, particularly when roles change within the organization.
Review and renew credentials as needed: IRS systems, including the FIRE account interface, may deactivate unused credentials or restrict access following inactivity. Organizations must log in periodically, review expiration notices, and renew or update credentials to avoid being locked out during key filing windows.
Track filing volumes across systems: Since electronic filing requirements apply based on the total number of returns submitted, nonprofits should track volumes across all systems, including IRIS and FIRE. Entities with multiple EINs or those managing filings for other businesses should combine counts to ensure they meet electronic filing thresholds.
Update responsible official information promptly: If a responsible official departs the organization, the nonprofit must request an update through the appropriate system. Failure to make these updates may delay return submissions or affect the organization’s ability to respond to system-generated notices.
Retain all submission records securely: Submitted files, system confirmation notices, and error reports should be stored securely in a central location within the organization. These documents are a reference point for audit requests, system rejections, or form amendments.
Review system notices and IRS updates: IRS communication, including annual updates to specifications, deadlines, and form requirements, must be reviewed consistently. Nonprofits should visit the appropriate resource pages annually, particularly in January, when the IRS releases updated filing requirements.
Refer to technical publications when formatting changes occur: Organizations must refer to the applicable system specifications to maintain compliance when IRS file structure changes or new form types are introduced. This is particularly important for returns processed through FIRE or those with international recipient requirements.
Long-term compliance depends on proactive system access management, clear internal procedures, and consistent attention to IRS filing developments. When nonprofits structure their processes around these practices, they minimize exposure to filing disruptions, reduce penalties, and enhance the reliability of their tax reporting cycle.
To meet TCC requirements for nonprofits, your organization must create a FIRE or IRIS account, submit an online application, and designate at least one responsible official. The IRS requires legal business information, including EIN, entity type, and officer details. Whether your nonprofit operates as a sole proprietor or house-based organization, these elements are mandatory for account admission and access. Without a valid TCC, e-filing of returns cannot proceed.
A sole proprietor running their company may file information returns if the business has a valid EIN and complies with IRS formatting and electronic filing rules. Even small nonprofits or individuals with low filing volume must meet the 10-return threshold if filing more than one type of form. The system does not make exceptions based on entity size. All electronic filings must follow approved system protocols.
The IRIS platform handles e-filing for Form 1099 series and supports individual information returns, while the new IR application replaced the legacy TCC application process. Filers can create a business account through the IRIS portal, verify a responsible official's identity, and submit test files. The new IR application requires submission through the IRS portal and cannot be mailed. Most organizations now apply online unless granted an exception.
An accurate IR application must include the organization’s legal name, EIN, the details of the responsible official, and any authorized delegates. Applicants must also provide identity verification and agree to the IRS’s user access agreement. The system requires complete information for timely admission, so reviewing before submitting is essential. Any mistakes could delay approval or limit access to critical IRS filing functions for the organization.
Yes, nonprofits may contact the IRS at the toll-free number on its assistance page for help with information returns, e-filing questions, or system access issues. Callers can request help in English or other supported languages. Before calling, gather your EIN, the details of the responsible official, and system login information to streamline the process. Depending on your filing platform, the IRS may direct you to the appropriate system helpdesk.
The issuer refers to the nonprofit organization reporting the payment or donation, such as scholarships, grants, or compensation. This entity must appear as the sender in all information returns and match the EIN and legal name registered with the IRS. Whether the filer is a house-run entity or a large nonprofit, the issuer must be clearly identified to ensure IRS matching and avoid rejection.
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