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NCFS Process Changes for Tax Year 2026

To: NCFS Agency Chief Financial Officers

From: Taylor Brumbeloe, Deputy State Controller NCFS Division

Subject: 1099 Process Changes for Tax Year 2026

The purpose of this communication is to inform NCFS agencies of important and major changes from the IRS regarding 1099 Tax Reporting. The IRS has retired the FIRE (Filing Information Returns Electronically) system currently used by OSC to file 1099s electronically on behalf of NCFS agencies. Starting tax year 2026, the IRS is requiring that 1099s be submitted to their new IRIS (Information Returns Intake System) portal.

OSC has reviewed the new portal guidelines and after extensive analysis has determined that it is no longer reasonable for OSC to file 1099s on behalf of NCFS agencies. Starting in January 2027 for the 2026 tax reporting year, each NCFS agency will become responsible for filing their own 1099s using the new IRIS portal.

There are several considerations impacting OSC’s analysis.

Original Transmission Process - The new IRIS portal only allows two methods for 1099 tax filing. Application to Application (A2A) and Template upload within the IRIS portal. The A2A method is not feasible due to the complexity and volume of statewide 1099 reporting and corrections across more than 40 legal entities.

NCFS will support the IRIS template process by providing a csv file of 1099 reporting data by form type (NEC, MISC, G) that can be added to the corresponding IRIS templates for upload in the portal.

Corrections Process - Once original 1099s are submitted within the IRIS portal, all 1099 corrections must be done manually within the IRIS portal. The original IRIS submission creates a record that can be manually selected and edited within the portal.

IRIS Portal Access – For OSC to continue 1099 filing for NCFS agencies, OSC would require access to each agency’s IRIS portal for original submissions and corrections. This would significantly increase risk and liability for human error. The IRIS portal will validate supplier information on submission of the 1099 file. Agencies know their suppliers best and will be better equipped to
resolve supplier errors during submission.

There are also several advantages for agencies with this new process.

Control Over Filing Timelines - Agencies will have more control over 1099 timelines and data submission and will not be dependent on OSC for submitting original files and corrections on their behalf. Corrections can be filed immediately within the IRIS portal rather than waiting for the OSC determined correction filing date.

Form Printing - The IRIS portal includes functionality for printing IRS approved 1099 forms in real time once the 1099 file is submitted to the IRS. Agencies will not be dependent on OSC to provide updated 1099 forms within our reports for printing.

Filing Extension - Agencies can choose to file a 30-day extension within the portal if needed for 1099s.

Corrections Process - Agencies will no longer need to record $0 invoices in NCFS for the corrections process since all corrections will originate in the IRIS portal. The IRIS portal will also replace the need for manual paper corrections after the OSC correction period has passed.

IRIS Application Process – The TCC application process is easy to complete and typically approved by the IRS quickly.

We understand that this is a major change for agencies, and OSC will still be available to provide support with this new process. OSC continues to work with Oracle to ensure that the system provided csv file works as expected with the IRIS portal upload template. OSC will also continue to support the NCFS 1099 Invoice Maintenance report in addition to holding future information sessions regarding the TCC Application Process and the IRIS Portal 1099 filing process.

Please monitor your email closely for future communications from OSC regarding next steps in setting up your agency’s IRIS Portal as well as information regarding required Delegation for Disbursing Authority (DDA) form updates.