10-Return E-file Rule 2025: IRIS Guide

Paper filing season is over for most small businesses. Since tax year 2023, if your company files 10 or more information returns in a calendar year, you must e-file—and you have to add the totals across return types. That means your W-2s, 1099-NECs, 1099-MISCs, 1099-Ks, 1095s, 1042-S, etc., all count toward the same 10-return threshold. The IRS built a free portal—IRIS (Information Returns Intake System)—to make this doable without buying software.

For multi-unit restaurants and franchise operators, this rule matters because you’re often issuing W-2s to dozens of employees and a stack of 1099-NECs to non-employee vendors. If you crossed 10 once, you’re in e-file world for good. Even your W-2s must be filed electronically with SSA’s Business Services Online when the combined count is 10 or more.

What changed (and what didn’t)

• Threshold & aggregation. The e-file threshold dropped from 250 per form to 10 in total, calculated by aggregating nearly all covered information returns.
• Corrections. If your original returns were required to be e-filed, your corrections must also be e-filed (but corrections don’t count toward the 10).
• Deadlines still matter. Most 1099s e-file to the IRS by March 31 (recipient copies by Jan 31). 1099-NEC and W-2 are due Jan 31—no “extra time” for e-filing those.
• Waivers exist but are narrow. If e-filing would cause undue hardship, you can request a waiver on Form 8508 (submit ~45 days before the due date).
• FIRE is being sunset for 1099s. The IRS is steering filers to IRIS; IRIS will be the only intake system for information returns for filing season 2027.

Your two e-file paths (and when to use each)

1) IRIS Taxpayer Portal (UI)—free, quick, and perfect for SMBs

Use this if you file a manageable number of forms and want a simple web experience.

• File up to 100 returns at a time (batch by CSV or type them in).
• Download recipient copies right from the portal.
• Keep a record of what you filed.
• You need an IRIS TCC (a 5-digit Transmitter Control Code unique to IRIS). Apply online.

2) IRIS A2A (Application-to-Application)—for volume or software workflows

Use this if you or your payroll/1099 software push thousands of forms.

• Requires an IRIS A2A TCC, an API Client ID, and passing Assurance Testing (ATS) before live filing.

Tip: Even if you use third-party software, confirm whether it files via IRIS under its own TCC or needs your IRIS TCC for compliance records.

Step-by-step: Set up and file through IRIS (Taxpayer Portal)

Step 1—Confirm you’re over the 10-return threshold.

Add up all information returns you’ll issue for the year (W-2s count toward the total). If the sum is 10+, you must e-file.

Step 2—Gather IDs and contacts.

Have your EIN, legal name, business address, and a primary contact ready. If a third party (bookkeeper/payroll) will help, document roles for data entry vs. final submission.

Step 3—Apply for an IRIS TCC (Taxpayer Portal)

The application is available on the IRIS website ("Apply for an IRIS Taxpayer Portal TCC"). Approval times vary, so do this before January.

Step 4—Choose your filing mode.

• Manual entry for a handful of forms.
• CSV upload for batches; download the IRS CSV template from inside IRIS to avoid format errors.

Step 5—Validate recipient data.

Common pain points: wrong TIN/name combos and bad addresses. Use your payroll/HRIS exports or a TIN-matching process to prevent reject notices.

Step 6—Create and review forms.

For restaurants and franchises, you’ll typically prep:

• W-2s (SSA BSO) for employees,
• 1099-NEC for independent contractors (due Jan 31),
• 1099-MISC for rents, prizes/awards, attorney payments, etc. (IRS e-file due Mar 31).

Step 7—Submit & archive.

E-file inside IRIS, then download recipient PDFs and your submission confirmations. Keep the CSV, acknowledgments, and any error logs with your month-end close package.

Step 8—Corrections.

If something changes, file corrected returns electronically (same method as original). Corrections don’t count against the 10, but they must be e-filed if your originals had to be.

Restaurant/Franchise pitfalls we fix most

1) “We mailed five, e-filed the rest.”

Mixing methods invites penalties and messy audit trails. If your total crosses 10, e-file them all, including W-2s via SSA BSO.

2) Wrong deadlines for 1099-NEC.

1099-NEC is due January 31 to recipients and the IRS—e-file doesn’t extend it. Build your payables calendar to cut checks early and finalize vendor totals by mid-January.

3) Unclear roles between franchisor, franchisee, and payroll vendor.

Decide who owns the IRIS TCC, who preps, who submits, and who stores the acknowledgments. Document the workflow so it survives turnover.

4) “We’ll use FIRE one more year.”

The IRS has announced IRIS will be the only intake system for information returns for filing season 2027. If you’re still on FIRE, start transitioning now.

5) Hoping for a waiver at the last minute.

Form 8508 waivers are for hardship, not convenience, and should be sent about 45 days before the due date. Keep your documentation tight if you apply.

A simple owner checklist (print this)

• Count your returns (aggregate across types). If 10+, plan to e-file all.
• Create your IRIS account & TCC (Taxpayer Portal).
• SSA BSO account ready for W-2 filing.
• Pick your mode: Manual vs. CSV; download the IRS CSV templates from IRIS.
• Clean vendor & employee data (names/TINs/addresses).
• Calendar due dates: W-2 and 1099-NEC Jan 31; most other 1099s Mar 31 if e-file.
• Archive PDFs, acknowledgments, and error logs with month-end.
• If needed: submit Form 8508 waiver early.

Why operators call QMK

QMK Consulting is an accounting firm in New York City specializing in franchise accounting and restaurant accounting. We build an end-to-end year-end workflow—vendor cleanup, TIN checks, IRIS setup, SSA BSO filing, and correction handling—so January isn’t chaos. Then we turn clean compliance into better cash flow: smarter pay schedules, cost controls, pricing, and a month-end close that tells you exactly where profit leaks.

If you’re juggling multiple units, third-party delivery platforms, and seasonal hiring, you don’t need another portal to learn—you need a process that just works.

👉 Need help? Get assistance from our experts and book your free Profit & Cash Flow Analysis today.

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