The practical answer

Keep a separate record for legacy FIRE access and the new IRIS arrangement, then connect them through the business workflow they serve. Track actual authorization and operational readiness independently instead of marking the whole migration complete when one code is found.

This register is an original project tool for the transition checked September 5, 2026. FIRE and IRIS TCCs are not interchangeable, and IRIS access must match the assigned filing method. IRM 3.42.9.7. This guide organizes evidence; it does not repeat the IRIS application tutorial.

Start with the workflows that must continue

List each legal organization, form family, source-data process, and historical transmitter arrangement. Include prior-year corrections, provider dependencies, and records that must remain available after routine FIRE work ends.

For each workflow, choose the planned destination: an authorized portal team, the organization's direct A2A software, or a provider that transmits on its behalf. The destination determines which access questions the register needs to answer.

Use stable internal labels for the workflow and credential records. Keep actual codes and sensitive access details in their controlled locations. The shared transition sheet should tell a reviewer where verified evidence exists without becoming a repository of passwords or private keys.

Keep FIRE and IRIS facts in separate records

Two-system register fields serve different purposes
FieldLegacy FIRE recordNew IRIS arrangement
Legal holderVerified old application entityVerified new transmitter or access holder
System and methodFIRE production/test contextPortal, direct A2A, or provider arrangement
Application evidenceExisting record and historical coverageActual application state and assigned access where applicable
Responsible administratorPerson able to answer legacy questionsPerson responsible for new access maintenance
Operating evidencePast file and status archiveApplicable tests, procedures, and outcome retrieval
Open actionMissing history or permitted maintenanceUnfinished access or implementation dependency

Do not overwrite the old system label with “IRIS” or copy a FIRE code into a new-code field. A historical relationship can stay useful even when the new transmitter is a different organization.

Separate application state from operational readiness

Record the exact observed application state and its date, then use a separate internal checklist for the work still needed. A completed application can coexist with unfinished data preparation or software testing. Conversely, a reviewed source file can exist while access is pending.

For direct A2A, track the applicable TCC, API Client ID, schema package, and ATS obligations with their actual responsible party. The IRS onboarding sequence and ATS guidance establish that additional work beyond finding a code is involved.

For a provider arrangement, record the confirmed division of responsibilities rather than assuming your organization performs every integration step. Identify who transmits, which source inputs are supported, and how detailed filing outcomes will be delivered.

Keep test and production evidence distinct. Do not mark a test result as production authorization or describe an unperformed test as complete because the process is documented.

Worked example: historical access is known, future operation is still pending

Fictional example. Example Property Group has verified its legacy FIRE application and located the prior NEC status archive. It plans to use a provider for tax year 2026 returns filed in 2027. The project spreadsheet initially says “credentials complete” because the old TCC record was found.

The two-system register reveals the missing work. The legacy side is documented, but the provider has not yet confirmed the unusual source-data cases or the method for delivering final acknowledgments. Those are operational dependencies in the new arrangement, even if no customer-owned direct A2A integration is planned.

The project changes its internal work state to “legacy record verified; new workflow confirmation pending.” It assigns a provider discussion with concrete questions and keeps the historical archive intact. This label is an internal planning description, not an IRS application status.

Plan legacy changes and records preservation around the actual cutoffs

The IRS's August 24, 2026 notice gives November 9 as the final date for changes to IR applications and November 19 at 3 p.m. Eastern as the final FIRE submission time. Mark those separately from the new workflow's internal target dates. IRS transition notice.

The FIRE webpage also contains broader December maintenance language. Use the explicit dated milestone for planning and verify current instructions before making a change, rather than assuming that the later prose extends the cutoff.

Before local decommissioning work, identify open legacy filing questions and the records needed to answer them. Preserve controlled access to the archive and the responsible contact chain. Closing a local integration or removing an employee's access is different from deleting filing evidence.

Review the register with evidence, not color alone

At each project check, open a sample evidence reference and confirm that it supports the claimed state. An acceptance letter should match the correct entity; an application screen should show the intended method; a test report should describe the actual environment and scope exercised.

List uncertainty explicitly: missing original-system evidence, unconfirmed provider support, an outstanding signature, or a pending software test. Give each a next action and responsible person. Avoid a single green cell that hides a partially completed arrangement.

When the new workflow is ready, record the scope it supports and the person responsible for reviewing the first real filing outcome. Keep the old register available for historical questions. The transition record should explain both where filing is going and how the organization will still understand what happened before.

Connect two access records through one business workflow

Connect two access records through one business workflow: Legacy FIRE context; Continuing workflow; New arrangement; Verified readiness
The connection is an internal workflow crosswalk. It does not transform or transfer a FIRE credential into IRIS access.
Read the workflow as text
  1. Legacy FIRE context. Verify holder, old coverage, administrator, and historical evidence.
  2. Continuing workflow. Identify legal payers, forms, source data, and correction needs.
  3. New arrangement. Record portal, direct A2A, or provider responsibilities separately.
  4. Verified readiness. Check real access, applicable tests, data support, and outcome retrieval.

Find filing options for your business

See the forms and services available through BoomTax, then choose the options that fit your organization's reporting needs.

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Put this guide to work

FIRE and IRIS credential transition register

Save the editable text worksheet and use it with your own records. Keep completed copies in your secure working files.

Download the worksheet TXT

Common questions

Can we rename the old FIRE TCC field to IRIS?

No. Keep the old record intact and verify the distinct new authorization or provider arrangement.

Does a completed application mean migration is finished?

No. Data support, applicable testing, operational procedures, and filing-outcome retrieval can still be pending.

Do provider customers need the same register as direct A2A operators?

They need a clear responsibilities and evidence record, but should mark direct-integration requirements according to the actual provider arrangement rather than assuming they perform them all.

Should the register contain API secrets?

No. Point to controlled access records and identify responsible administrators. Keep secrets out of the general project sheet.

What happens to the legacy side after cutover?

Retain the ownership and filing-evidence context for historical questions and required records. A new workflow does not erase the old filing history.

Official sources and scope

Sources checked September 5, 2026. Use the edition for the tax year and filing method you are working with; later instructions may change thresholds, fields, or procedures.

  1. IRS IRM 3.42.9.7

    Distinct FIRE/IRIS authorizations and method-specific IRIS TCC context.

  2. IRS: E-file information returns with IRIS

    Portal/A2A arrangements and direct A2A onboarding components.

  3. IRS: ATS

    Testing responsibilities remain separate from application completion.

  4. IRS transition notice, August 24, 2026

    Explicit November legacy application/submission milestones.

  5. IRS: FIRE retirement guidance

    Current retirement context; broader December text must not be treated as overriding the dated November cutoff.