The infrastructure of US tax reporting is undergoing a massive transformation. The IRS is officially retiring the legacy Filing Information Returns Electronically (FIRE) system at the end of 2026.
Starting in the 2027 filing season, the Information Returns Intake System (IRIS) will take over. However, accessing IRIS requires authorized users to authenticate using a US taxpayer identification number (such as an SSN or ITIN).
This creates a massive roadblock for foreign financial institutions, trusts, and exporters. If your authorized users do not possess a US TIN, you will be locked out of the standard IRIS portal. To prevent a compliance disaster for entities submitting Forms 1042-S, applicable 1099s, and FATCA reports, the IRS has launched the Foreign Filer TCC Registration System.
Here is exactly how this impacts your institution, and how the division of labor between your internal team and your technical compliance software works.
The Administrative Requirement: You Need a Foreign Filer TCCThe new Foreign Filer TCC Registration System is a dedicated pathway designed strictly for eligible foreign filers whose responsible officers lack a US SSN or ITIN.
Registering through this system grants you a specific Global Intermediary Identification Number (TCC GIIN) and a Transmitter Control Code (TCC). These credentials are your keys to unlocking enrollment in the International Data Exchange System (IDES), which will serve as your transmission gateway in 2027.
(Note: If your authorized users do have a US TIN, you must use the standard IRIS portal, not this system).
The Division of Labor: Administration vs. Technical ExecutionWhen adapting to this new IRS framework, it is crucial to separate the administrative registration from the technical data execution.
1. Your Role: Securing AccessSecuring the TCC and gaining access to the IDES portal is an administrative task that your institution must handle directly. Because you are the official transmitter of your own data, you must secure the credentials. The IRS warns against waiting until the filing season, as there is a built-in delay.
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Authenticate: Your responsible officer must create an account via Login.gov or ID.me using an email that matches your Foreign Filer TCC account exactly.
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Register: Log into the new system to create your Foreign Filer ID, obtain your TCC GIIN, and request your TCC.
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Wait: You must wait three to six weeks for IRS systems to sync before attempting IDES enrollment.
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Enroll: Secure an Authorized Security Certificate from an approved provider to finalize your IDES access.
You might wonder: Does Novus Compliance need to register for this TCC on our behalf?
The answer is no. Novus Compliance operates strictly as a technical enabler, not a full-service filing agent or third-party transmitter.
Gaining access to the IDES portal is only the first step. IDES does not accept raw spreadsheets or PDFs. The portal demands a perfectly formatted XML schema that is digitally signed and cryptographically locked using AES-256 encryption.
This is where we take over. You handle the ID.me verifications and secure your transmission credentials; we handle the code. You feed your operational data into our platform, and we programmatically map it to the exact IRS-mandated XML schemas. We apply the AES-256 encryption and package the final, secure .zip file.
Your internal team simply takes this flawless, encrypted payload and uploads it directly to IDES using the new Foreign Filer TCC credentials you secured.
By decoupling the administrative transmission from the technical XML generation, you maintain absolute control over your compliance submissions while completely eliminating the technical friction of IRS data packaging.