IRIS Filing Guide for Insurance Companies

How the FIRE Shutdown Affects Insurance Companies

Insurance companies are high-volume filers of several information return types that flow through the FIRE system. Life insurance carriers, annuity providers, health insurers, and property/casualty companies all have information return obligations that require electronic filing. When the FIRE system permanently shuts down on December 31, 2026, every one of these filings must transition to IRIS.

For most insurers, the year-end reporting pipeline is deeply embedded in policy administration systems (PAS), claims management platforms, and benefits administration software. These systems generate Publication 1220-format flat files that have been uploaded to FIRE for decades. Updating these systems to generate IRIS XML is a significant undertaking — and for legacy mainframe-based systems common in the insurance industry, it may not be feasible within the timeline.

Insurance-Specific Forms Affected by the FIRE Shutdown

The 1099-R alone represents enormous filing volume for insurance companies. A large life insurance and annuity carrier may file hundreds of thousands of 1099-R forms annually — one for every policy surrender, annuity distribution, pension payout, and retirement plan distribution. These forms carry complex distribution coding that must be translated precisely when moving from FIRE to IRIS.

Distribution Codes: FIRE Format vs. IRIS XML

The 1099-R distribution code is one of the most critical data elements on the form. It tells the IRS and the recipient what type of distribution occurred and how it should be taxed. In the FIRE (Publication 1220) format, the distribution code occupies a specific fixed-width field position within the B (payee) record. In IRIS XML, it maps to a structured element with enumerated valid values.

Common distribution codes that insurance companies must handle correctly:

• Code 1: Early distribution, no known exception (subject to 10% penalty)
• Code 2: Early distribution, exception applies (Roth IRA conversion, etc.)
• Code 3: Disability
• Code 4: Death (paid to beneficiary or estate)
• Code 7: Normal distribution (age 59½ or older)
• Code D: Annuity payments under IRC Section 72(e)(11)
• Code G: Direct rollover to qualified plan, 403(b), governmental 457(b), or IRA

In the FIRE format, these are single-character codes in a known position. In IRIS XML, they are elements that must match the IRS schema's enumerated values exactly. A mapping error during conversion can trigger IRS rejections or, worse, incorrect tax reporting for policyholders. BoomTax's conversion engine maps every valid FIRE distribution code to the corresponding IRIS XML element, with validation rules that flag any unrecognized codes before submission.

HSA and Medical Savings Account Reporting

Health insurers and benefits administrators who serve as HSA or MSA custodians face a dual reporting obligation:

• 1099-SA reports distributions from the account — the health insurer must report every withdrawal, including qualified medical expense reimbursements, excess contribution returns, and prohibited transactions
• 5498-SA reports contributions and the fair market value of the account as of December 31 — this includes employer contributions, employee contributions, and rollovers

Both forms have different filing deadlines. The 1099-SA is due by March 31 (for electronic filing), while the 5498-SA is due by June 2. Under FIRE, many insurers batch both form types into their year-end filing pipeline. Under IRIS, the same approach works — but the underlying file format must change from fixed-width to XML. With BoomTax, insurers can continue generating their FIRE-format export for both form types and let BoomTax handle the conversion and staggered filing.

State Filing Requirements for Insurance Companies

Insurance companies operate across multiple states, and many states require copies of information returns filed with the IRS. The Combined Federal/State Filing Program (CF/SF) simplifies this by forwarding federal filings to participating states automatically.

Key considerations for insurance companies during the FIRE-to-IRIS transition:

• CF/SF participation carries forward: If you participate in the Combined Federal/State Filing Program through FIRE, IRIS supports the same program. Your state filing obligations don't change.
• State withholding data: Many 1099-R forms include state income tax withheld. These fields must map correctly from FIRE format to IRIS XML — BoomTax preserves all state withholding data during conversion.
• Non-participating states: For states not in the CF/SF program, you'll need to continue filing directly with those state agencies. BoomTax can generate the appropriate state filings separately.
• Multi-state annuity distributions: When an annuitant moves between states during the tax year, the allocation of distributions across states becomes complex. The underlying reporting rules don't change with IRIS, but your data must be correct in the new format.

Policy Administration System Compatibility

Insurance companies rely on policy administration systems (PAS) that generate year-end tax reporting files. These systems — whether from Guidewire, Duck Creek, Majesco, EXL, or custom mainframe applications — typically export in Publication 1220 format. Modifying these exports to generate IRIS XML involves:

• Engaging the PAS vendor for an IRIS-compatible release (if available)
• Testing against IRS XML schemas for every form type
• Validating distribution codes, amount fields, and TIN formatting in the new structure
• Updating internal audit procedures that reference FIRE-format file layouts
• Change management and regulatory review processes that can span months

BoomTax eliminates this dependency. Keep your PAS generating the same FIRE-format files. Upload them to BoomTax. We parse the FIRE records, convert to IRIS XML, validate every field against IRS schemas, and submit through IRIS. Your policy administration system doesn't change. Your export routines don't change. Your audit trail continues seamlessly.

Timeline for Insurance Companies

For the complete transition timeline, see our FIRE-to-IRIS transition timeline.

Frequently Asked Questions

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