On Nov. 19, 2026, at 3 p.m. Eastern, the IRS will stop accepting filings through FIRE, the Filing Information Returns Electronically system that organizations and their accountants have used for decades to e-file 1099s and other information returns. The agency issued a reminder on Aug. 24 that FIRE users must move to its replacement, the Information Returns Intake System, known as IRIS, to file their tax year 2026 returns next filing season. The IRS's FIRE transition page goes further: after Jan. 1, 2027, IRIS will be the only IRS e-file system for the returns FIRE handles, including prior-year returns and corrections.
For most nonprofits this lands in a specific place: January. If your organization paid an independent contractor $2,000 or more this year, someone has to file a Form 1099-NEC for tax year 2026 early next year, and FIRE will be gone by then. That dollar figure is new too: the 2025 tax law raised the reporting threshold from the long-standing $600 to $2,000, starting with payments made in 2026 and indexed for inflation after that, though you still must file for anyone you took backup withholding from, at any amount. The usual carve-outs also still apply: payments to corporations are generally exempt, with attorneys' fees the notable exception, and anything you paid by credit card or through a payment platform gets reported by the processor on Form 1099-K, not by you.
Most Small Nonprofits Never Touch FIRE, and That Is Fine
Start with what is probably already handled for you. If a payroll provider, your accountant, or a 1099 e-file service files your information returns, the FIRE shutdown is their problem, not yours. The transition work happens on their side, and the industry has had long notice: IRIS has been live since January 2023. Your only job is a one-line email asking them to confirm they are ready to file your tax year 2026 forms through IRIS.
The organizations with work to do are the ones that e-file their own returns directly through FIRE, or that have been filing on paper. Since tax year 2023, any filer with 10 or more information returns in a year, counting W-2s and every other information return type along with 1099s, has been required to file them electronically. A nonprofit with a handful of employees and a few contractors crosses that line without noticing. There is a relief valve for organizations that truly cannot e-file, a hardship waiver requested on Form 8508, but treat it as the exception it is, not the plan.
Your FIRE Credentials Will Not Carry Over
IRIS requires its own Transmitter Control Code, the five-character ID the IRS uses to identify e-filers, and a FIRE code does not transfer. The IRS has stopped accepting new FIRE applications entirely, and its published timeline gives current users three dates: Nov. 1 is the last day to file test returns through FIRE's test system, Nov. 9 is the last day to make changes to an existing FIRE application, and Nov. 19 at 3 p.m. Eastern is the last day to file.
The catch is processing time. The IRS advises applicants to allow up to 45 calendar days for an IRIS application to be processed, and its step-by-step application guide, Publication 5903, says typical applications process within 45 business days, which is closer to nine weeks. An organization that waits until January to apply may not have its code when tax year 2026 Forms 1099-NEC come due on Feb. 1, 2027, the deadline this cycle because Jan. 31 falls on a Sunday. Apply this fall, not after the holidays.
IRIS Is Free, and Small Filers Get the Simple Version
The good news is that IRIS costs nothing and its Taxpayer Portal was built for exactly the small-filer case: you can key in forms by hand or upload a CSV file, up to 100 returns per submission, and file corrections through the same screen. The separate application-to-application channel is for software companies and bulk transmitters, and a typical nonprofit can ignore it. You will need your EIN to apply, and the person applying signs in through ID.me, the same identity verification the agency uses for its Business Tax Account. Fair warning for all-volunteer boards: the responsible official on the application provides a Social Security number or ITIN, date of birth, and citizenship status, so pick that person deliberately.
If your organization is new to all of this, the January 1099 cycle is one of the deadlines that catches first-time EDs off guard. Add it to the annual filings new nonprofits already track, alongside the ones in the first-year compliance calendar.
What to Do Before Thanksgiving
Three items, in order. First, find out how your 1099s were filed last January: a provider, an accountant, FIRE, or paper. Ask whoever ran it. Second, if the answer is a provider or accountant, get their written confirmation that they are IRIS-ready and stop there. Third, if the answer is FIRE or paper and you expect 10 or more information returns, apply for an IRIS Transmitter Control Code now and calendar a test filing for December. The application is free, but count backward: even the shorter 45-day processing estimate, started in mid-November, runs into the new year, and January is too late to start.
The Takeaway
The FIRE shutdown is not a policy change, and nothing about what your nonprofit owes or reports is different. It is an infrastructure swap with a hard cutoff in the middle of the quietest stretch of the fiscal year, which is exactly how organizations get surprised in January. Spend 20 minutes this fall confirming who files your 1099s and how, and the transition will be someone else's memo.