IRIS Filing Guide for Banks and Financial Institutions

Why the FIRE Shutdown Is a Major Event for Financial Institutions

Banks and financial institutions are among the largest filers of information returns in the United States. A single mid-size bank may file hundreds of thousands of 1099 forms annually — 1099-INT for every interest-bearing account, 1099-DIV for dividend distributions, 1099-R for retirement account distributions, and 1099-B for brokerage transactions. Large banks and broker-dealers file millions.

For the past 25+ years, these filings have flowed through a well-established pipeline: the core banking system generates a Publication 1220-format file, the operations or tax department uploads it to the IRS FIRE system, and the acknowledgment comes back. This pipeline is embedded in regulatory processes, internal controls, and audit procedures. It works — and on December 31, 2026, it ends.

The replacement, IRIS (Information Returns Intake System), uses a fundamentally different architecture. Instead of fixed-width flat files, IRIS accepts XML. Instead of a simple file upload, IRIS offers a manual web portal (impractical at banking volumes) or an Application-to-Application (A2A) API channel that requires significant integration work. For financial institutions operating under strict regulatory and audit requirements, this transition requires careful planning, testing, and stakeholder alignment.

What Banks File: The Scale of the Problem

Financial institutions typically file the following information returns in large volumes:

Form	Purpose	Typical Volume at Banks
1099-INT	Interest income paid on savings, CDs, money market accounts	One per account earning $10+ interest — often the largest single form type
1099-DIV	Dividends and capital gains distributions	One per investment account with distributions — high volume at wealth management divisions
1099-R	Distributions from IRAs, pensions, annuities	One per retirement account distribution — significant at institutions with IRA custodial services
1099-B	Proceeds from broker and barter exchange transactions	One per sale — extremely high volume at broker-dealers; complex cost-basis reporting
1099-OID	Original issue discount on bonds and notes	Common at institutions that issue or hold discounted debt instruments
1099-SA / 5498-SA	HSA distributions and contributions	Growing volume as banks serve as HSA custodians
1099-MISC	Miscellaneous payments (prizes, legal settlements)	Lower volume but still present — promotional prizes, legal settlements

At these volumes, the IRIS Taxpayer Portal — which limits CSV uploads to 100 forms per file — is not a viable path. A bank filing 500,000 1099-INT forms would need 5,000 separate uploads. The A2A channel is the only realistic IRS-direct option, but it requires a substantial engineering investment.

Core Banking Systems and the FIRE Format

The FIRE-format export is deeply embedded in core banking platforms. The three major core providers in the U.S. — FIS, Fiserv, and Jack Henry — all generate Publication 1220-compliant files as part of their year-end tax reporting modules. So do most other banking platforms, including Temenos, Finastra, and nCino.

The Core Banking Integration Challenge

Updating a core banking system's tax reporting module is not a simple configuration change. These systems are tightly regulated, heavily tested, and change-controlled. A modification to the 1099 export routine typically requires:

• Vendor coordination: If your core provider (FIS, Fiserv, Jack Henry) offers an IRIS XML export, you need to upgrade to the version that supports it, validate the output, and integrate it into your existing workflows
• Regulatory testing: Any change to tax reporting output must be tested against IRS specifications and validated by your compliance team
• Change management: Core banking changes typically go through a formal change advisory board (CAB) process with months of lead time
• Audit trail continuity: Your existing audit procedures reference FIRE-format files and FIRE acknowledgments — these procedures need updating
• Parallel run requirements: Regulators and auditors often expect parallel processing during a transition to validate output consistency

For many financial institutions, waiting for the core banking vendor to ship an IRIS-native export may not be feasible within the timeline. And even if the vendor delivers, the internal testing and change management process can add months.

The Faster Path: Keep FIRE Format, Use BoomTax for IRIS

BoomTax eliminates the core banking dependency entirely. Keep generating the same FIRE-format (Publication 1220) files your core system already produces. Upload them to BoomTax. We parse the FIRE records, convert to IRIS XML, validate against IRS schemas, and submit through IRIS on your behalf.

Your core banking system doesn't change. Your export routine doesn't change. Your file format doesn't change. Only the destination changes — from FIRE to BoomTax.

Compliance and Audit Trail Requirements

Financial institutions operate under regulatory frameworks — OCC, FDIC, Federal Reserve, state banking regulators — that impose specific requirements on information return filing. The FIRE-to-IRIS transition raises several compliance considerations:

Regulatory Reporting Continuity

Examiners expect your institution to demonstrate that tax information returns are filed accurately, completely, and on time. The IRIS transition changes the technology but not the obligation. Your compliance team needs to verify that:

• Every account meeting the reporting threshold has a corresponding 1099 filed
• Amounts reported match general ledger entries and account statements
• TINs are validated and backup withholding is applied where required
• Filings are submitted by the applicable deadline to avoid penalties
• Corrections are filed promptly when errors are discovered

How BoomTax Supports Banking Compliance

• Complete audit trail: Every file upload, validation result, submission, and IRS acknowledgment is logged with timestamps and user attribution
• Pre-submission validation: BoomTax validates TIN formats, amount fields, required data elements, and IRS business rules before submitting to IRIS — catching errors before they become regulatory findings
• Acknowledgment tracking: IRS acceptance and rejection status is tracked per form, per payer, with clear error descriptions. No more parsing cryptic FIRE acknowledgment codes
• Correction management: File corrected returns through the same platform with full tracking of what was changed, when, and why
• SOC 2 alignment: BoomTax maintains security controls appropriate for handling sensitive financial data and PII

IRIS XML: What Changes at the Technical Level

For IT teams evaluating the scope of a direct IRIS integration versus using BoomTax, here's what the technical migration involves:

Aspect	FIRE (Current)	IRIS A2A (Direct)	BoomTax
File format	Fixed-width text (Pub 1220)	XML (IRIS schema)	Accept FIRE format — convert internally
Submission	HTTPS file upload	SOAP web services	Web upload, REST API, or SFTP
Authentication	TCC + username/password	TCC + digital certificate	BoomTax account (no TCC needed)
TCC application	Already have one	New application, 45+ days	Not required
Development effort	Existing (sunk cost)	3-6 months for XML + SOAP	Days — upload existing file
Schema updates	Pub 1220 updates annually	IRS XML schema updates	BoomTax handles schema changes
Volume capacity	Millions of records per file	Large batches via API	Unlimited — enterprise scale

For institutions that want to understand the IRIS XML format in detail, see our FIRE to IRIS XML conversion guide. For a broader comparison of the two IRS systems, read IRIS vs FIRE compared.

Core Banking Platform Compatibility

BoomTax accepts FIRE-format files from any core banking system that exports in Publication 1220 format. This includes:

If your core system produces a valid Publication 1220 file with standard T/A/B/C/F record structures, BoomTax can process it — regardless of which vendor or platform generated it. See our FIRE file upload guide for details.

Timeline for Banks: What to Do Before December 31, 2026

Given the regulatory, compliance, and change management requirements at financial institutions, the earlier you start, the smoother the transition. Here's a recommended timeline:

Timeframe	Action
Now (Q2 2026)	Inventory all FIRE-based filing processes. Identify which core systems generate Publication 1220 files, what form types are included, and what volumes are involved. Engage your core banking vendor to understand their IRIS roadmap.
Q2-Q3 2026	Establish a BoomTax enterprise account. Upload a sample FIRE file from your core system to validate compatibility. Engage compliance and internal audit teams on the transition plan.
Q3 2026	Conduct a parallel test: process a batch of test 1099-INT or 1099-DIV records through BoomTax alongside your existing FIRE process. Validate output consistency. Document the new process for audit purposes.
Q4 2026	Finalize the transition plan. Update internal procedures, audit documentation, and compliance checklists. Train operations staff on the BoomTax workflow. Prepare for Tax Year 2026 filing.
Tax Year 2026 Filing (Jan-Mar 2027)	File exclusively through BoomTax/IRIS. FIRE is no longer available. Your core system exports the same file; BoomTax handles IRIS submission. Monitor acknowledgments and handle corrections through the platform.

Frequently Asked Questions

For related industry guidance, see our IRIS filing guides for CPAs and accountants and payroll and HRIS companies. For the full migration walkthrough, read how to migrate from FIRE to IRIS.