IRIS Filing Guide for Payroll and HRIS Companies

Why the FIRE Shutdown Matters More for Payroll Companies

Payroll and HRIS companies occupy a unique position in the 1099 filing ecosystem. You don't just file for one payer — you file for hundreds or thousands of employer clients, each with their own contractors, vendors, and payment recipients. The FIRE system shutdown isn't just a format change; it's a disruption to the batch processing pipelines that your business depends on.

Under FIRE, most payroll companies built automated workflows: extract contractor payment data from the payroll system, generate a Publication 1220-format file with T/A/B/C/F records, upload to FIRE in bulk, and download acknowledgments. These pipelines often run with minimal human intervention. They've been refined over years. They work.

IRIS changes the technical foundation of that entire pipeline. The file format shifts from fixed-width text to XML. The submission mechanism moves from a simple file upload to either a manual web portal or an API-based Application-to-Application (A2A) channel. And the TCC requirements are stricter, with more involved vetting for transmitter authorization.

For payroll companies handling thousands of 1099 forms across hundreds of clients, this is not a weekend project. It's a significant engineering effort — unless you use a platform that bridges the gap.

What Payroll Companies File and Why It Matters

Payroll and HRIS companies typically handle the following information returns on behalf of their clients:

• 1099-NEC (Nonemployee Compensation): The primary form for independent contractor payments. This is the highest-volume 1099 form for most payroll companies, as clients use the payroll system to track contractor payments alongside employee wages.
• 1099-MISC (Miscellaneous Income): Used for rent payments, prizes, legal settlements, and other non-contractor payments that don't belong on 1099-NEC. Many payroll clients have a mix of both.
• 1099-INT (Interest Income): Less common for payroll companies, but some handle this when clients have interest-bearing accounts or notes payable.
• 1099-DIV (Dividends): Relevant for payroll companies that also handle equity compensation or dividend distributions.

The volume matters. A mid-size payroll company might file 50,000 to 200,000 1099-NEC forms annually across its client base. Large payroll bureaus handle millions. At these volumes, manual entry through the IRIS Taxpayer Portal is not an option. You need a bulk submission path — and that means either building an IRIS A2A integration or using a platform like BoomTax.

The Integration Challenge: ADP, Paychex, Paylocity, and Others

Most payroll companies have built their 1099 export around the FIRE format because that's what the IRS accepted for 25+ years. Whether your platform is ADP Workforce Now, Paychex Flex, Paylocity, UKG, Gusto, or a custom-built system, the export likely follows Publication 1220 specifications.

What Needs to Change

Component	Under FIRE	Under IRIS
Export format	Fixed-width text (Pub 1220)	XML (IRIS schema)
Submission method	File upload to fire.irs.gov	SOAP web service (A2A) or web portal
Authentication	FIRE TCC + credentials	IRIS TCC + digital certificate
Acknowledgment	Downloadable acknowledgment file	API response or portal status
Error handling	Parse acknowledgment codes	XML error responses via API
Testing	FIRE test system	IRIS A2A test environment

The Engineering Effort

If you maintain your own filing pipeline, migrating to IRIS A2A requires:

1. Applying for an IRIS TCC — a 45+ day process with background checks for responsible officials
2. Rewriting the export layer — converting from Publication 1220 fixed-width output to IRIS-compliant XML (see our FIRE to IRIS conversion guide)
3. Building SOAP integration — implementing the A2A web service calls for submission, status checking, and acknowledgment retrieval
4. Handling digital certificates — procuring and managing the certificates required for A2A authentication
5. Testing and certification — completing the IRS's testing requirements before going live
6. Updating error handling — rewriting acknowledgment parsing for XML-based error responses
7. Maintaining ongoing compliance — the IRS updates IRIS schemas periodically, requiring code updates

For large payroll companies with dedicated engineering teams, this is feasible but expensive. For mid-size providers, it may consume the entire development budget for a quarter or more. For smaller payroll bureaus, it's often not practical at all.

Volume Challenges: Filing Thousands of 1099s Through IRIS

IRIS was built to handle volume — but the two channels serve very different scale needs:

• IRIS Taxpayer Portal: Supports CSV uploads of up to 100 forms per file. At 50,000 forms, that's 500 separate uploads. Not viable for payroll companies.
• IRIS A2A: Supports large XML submissions through the SOAP API. This is the intended path for high-volume filers, but it requires the full engineering investment described above.

The volume challenge extends beyond submission. Payroll companies also need to handle:

• Multi-payer batching: Filing for hundreds of employer clients in a single processing run
• Mixed form types: A single client might need 1099-NEC for contractors and 1099-MISC for rent or legal payments
• Corrections at scale: When a client provides updated contractor TINs or amounts after filing, corrections need to flow through efficiently
• Recipient copy fulfillment: IRIS only handles the IRS copy. Payroll companies still need to deliver Copy B to every payee — thousands of individual mailings or electronic deliveries
• Audit trail: Clients expect detailed reporting on what was filed, when, and with what status

BoomTax for Payroll Companies: Keep Your Exports, Skip the Rewrite

BoomTax is purpose-built for exactly this scenario. Instead of rewriting your export pipeline, keep generating the same FIRE-format files your systems already produce and let BoomTax handle the IRIS submission.

How It Works

Why Payroll Companies Choose BoomTax

• No pipeline rewrite: Your ADP, Paychex, Paylocity, or custom payroll system keeps generating FIRE-format files. BoomTax bridges the gap to IRIS.
• No TCC application: BoomTax holds the IRIS TCC. You don't need to apply, wait 45+ days, or manage digital certificates.
• Unlimited volume: File 50,000 or 500,000 forms — BoomTax handles payroll-scale volumes without the 100-form portal limit.
• Multi-payer in one upload: A single FIRE-format file with hundreds of payers (A records) processes into individual IRIS submissions per payer automatically.
• API integration: For payroll companies that want to automate the BoomTax step, the REST API supports programmatic file upload, status checking, and acknowledgment retrieval.
• White-label options: Offer 1099 filing as a native feature of your payroll platform. BoomTax processes behind the scenes under your brand.
• Recipient copy fulfillment: BoomTax prints and mails Copy B to payees or delivers electronically with consent — one less thing for your operations team to manage.
• Per-client reporting: Give each employer client visibility into what was filed, accepted, or rejected — the audit trail your clients expect from their payroll provider.

Timeline for Payroll Companies: What to Do Before December 31, 2026

The FIRE shutdown date is December 31, 2026. Payroll companies should plan their transition well in advance — your clients depend on you for compliant, on-time filing. Here's the recommended approach:

Timeframe	Action
Now (Q2 2026)	Evaluate your current FIRE pipeline. Identify every system that generates Publication 1220 files. Determine whether your payroll platform vendor plans to support IRIS natively.
Q2-Q3 2026	Set up a BoomTax account. Upload a test FIRE file to verify compatibility with your export format. Test the API if you plan to automate the upload step.
Q3-Q4 2026	Run a parallel test: file Tax Year 2025 returns through both FIRE (while available) and BoomTax. Validate that BoomTax produces identical results.
Tax Year 2026 Filing (Early 2027)	File exclusively through BoomTax/IRIS. FIRE is no longer available. Your pipeline exports the same file; only the submission destination changes.

Payroll Platform Compatibility

BoomTax accepts FIRE-format files from any payroll or HRIS system that exports in Publication 1220 format. This includes — but is not limited to:

If your system produces a valid Publication 1220 file with T/A/B/C/F records, BoomTax can process it. For details on the upload process, see our FIRE file upload guide.

Frequently Asked Questions

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