Tribal casino operators are heading into a busy summer season, but the winter tax filing requirements on the horizon demand attention now, not later. For compliance and accounting teams, H2 is the window to get ahead of reporting obligations, if not already completed — before the year-end crunch leaves little room for course corrections.
The One Big Beautiful Bill Act (OBBBA), enacted July 4, 2025, raised the general information reporting threshold under Section 6041 to $2,000 for tax year 2026—with annual inflation adjustments beginning in 2027. For tribal casinos, this touches two distinct compliance functions that typically sit in different departments and should be addressed separately: gaming floor and cage operations, where W-2G thresholds rise for slots, keno, and sports wagering and 1099-MISC triggers update for patron prizes and promotional giveaways; and accounts payable, where the reporting floor for vendor, contractor, and royalty payments lifts from $600 to $2,000. A full breakdown of both—including when withholding obligations are triggered—is covered in a companion article: “A Guide for Casinos for the 2026 Reporting Threshold Changes,” which can be obtained at: https://www.inforeportingsolutions.com/self-assessment-quick-check.html.
The FIRE to IRIS Migration
For more than four decades, tribal casinos filed their information returns — W-2Gs, 1099s, 1042-S forms — through the IRS FIRE (Filing Information Returns Electronically) system. That system is being shut down permanently on December 31, 2026. Beginning with tax year 2026 filings processed in early 2027, all electronic information returns must go through IRIS (IRS Information Returns Intake System).
This is not a platform upgrade. The underlying data architecture is fundamentally different:
- FIRE accepted fixed-width ASCII text files formatted under Publication 1220 — a format that third-party software could generate, with casinos uploading the resulting files directly to the IRS.
- IRIS requires structured XML schemas with real-time field-level validation at the moment of ingestion. Certain field-level errors—most notably name/TIN mismatches—are flagged immediately as “accepted with errors,” requiring a corrected filing within 60 days. Other issues, such as missing required fields or schema-level formatting violations, can cause the entire transmission to be rejected outright rather than accepted with a flag. Under FIRE, the contrast was stark: a file was rejected only if its schema did not conform to the FIRE layout requirements—typically a structural issue, not a problem with missing or incorrect data points. A name/TIN mismatch, by contrast, would pass through FIRE undetected and not surface until a CP2100 notice arrived months later.
- Data fields differ. Some fields that FIRE accepted as combined (e.g., full name in a single field) must be separated in IRIS (first name and last name as distinct fields). Existing data pipelines and CMS exports may require restructuring before they are IRIS-compliant.
- The TCC is their credential to obtain and maintain — they file under their own authorization. Your FIRE TCC, if you ever had one, is irrelevant.
- Your responsibility is to confirm, in writing, that your provider holds an IRIS TCC, is fully IRIS-ready, and has completed IRS testing. Do not assume. Ask for documentation.
- Verify that their system can accept your data in the format you currently export and convert it correctly to IRIS XML.
- You need your own IRIS TCC. The application process can take up to 45 days, so this should already be underway.
- IRIS offers two filing methods, and the distinction matters:
- Manual (UI) filing — direct entry through the IRIS web portal. There is no cap on the number of files you can submit, but each file is limited to 250 records. For properties with large W-2G or 1099 volumes, this means breaking filings into many small batches — workable for modest volumes, but operationally impractical at scale.
- A2A (Application-to-Application) API — automated machine-to-machine submission for high-volume filers. This is not a software purchase in the way FIRE-era tools were. A2A requires either building a direct API integration or engaging a service provider who will convert your data and submit on your behalf. It requires IRS Automated Transmission System (ATS) testing before go-live.
- The old FIRE workflow — buy software, generate an ASCII file, upload it — does not have a direct equivalent in IRIS for high-volume filers. If your property files large volumes of W-2Gs or 1099s, A2A is the appropriate path, and securing that capability requires lead time.
Self-Filing vs. Third-Party Filing: Two Different Problems
Any entity filing information returns electronically with the IRS must hold a Transmitter Control Code (TCC) — a credential issued by the IRS that authorizes electronic filing. FIRE TCCs and IRIS TCCs are separate credentials; a FIRE TCC does not carry over to IRIS and cannot be used to file through the new system. How a casino handles this depends on who is doing the filing:
If you use a third-party reporting provider:
- The TCC is their credential to obtain and maintain — they file under their own authorization. Your FIRE TCC, if you ever had one, is irrelevant.
- Your responsibility is to confirm, in writing, that your provider holds an IRIS TCC, is fully IRIS-ready, and has completed IRS testing. Do not assume. Ask for documentation.
- Verify that their system can accept your data in the format you currently export and convert it correctly to IRIS XML.
If you self-file:
- You need your own IRIS TCC. The application process can take up to 45 days, so this should already be underway.
- IRIS offers two filing methods, and the distinction matters:
- Manual (UI) filing — direct entry through the IRIS web portal. There is no cap on the number of files you can submit, but each file is limited to 250 records. For properties with large W-2G or 1099 volumes, this means breaking filings into many small batches — workable for modest volumes, but operationally impractical at scale.
- A2A (Application-to-Application) API — automated machine-to-machine submission for high-volume filers. This is not a software purchase in the way FIRE-era tools were. A2A requires either building a direct API integration or engaging a service provider who will convert your data and submit on your behalf. It requires IRS Automated Transmission System (ATS) testing before go-live.
- The old FIRE workflow — buy software, generate an ASCII file, upload it — does not have a direct equivalent in IRIS for high-volume filers. If your property files large volumes of W-2Gs or 1099s, A2A is the appropriate path, and securing that capability requires lead time.
Understanding the State Reporting Landscape
A federal threshold update does not mean every state has caught up. Many state revenue departments and gaming compact provisions remain tied to the old, pre-OBBBA dollar thresholds, since a federal statutory change does not automatically amend state law or compact terms. The filing side adds another layer: most states still require information returns in the legacy Publication 1220 ASCII format rather than IRIS’s XML schema, and only a limited number participate in the IRS’s Combined Federal/State Filing program through IRIS. A casino that files federally through IRIS may still need to prepare and submit a separate ASCII file to satisfy a given state’s requirements. A forthcoming article will take a closer look at how these state-level gaps interact with the federal changes and what tribal operators should be tracking.
The Directive: Put a Documented Compliance Plan in Place Today
Tax compliance is a mission-critical component of a tribe’s operational infrastructure and audit security.
With the summer rush in full swing, casino executives should not wait until year-end to find out whether their property is ready for these changes. Whether your casino files directly or relies on a third-party provider, the question is the same: do you have a written compliance plan that spells out who is responsible for each piece—IRIS readiness, TCC status, W-9 and W-8 collection, withholding triggers, and state-level obligations—and confirms each one is on track? Do not assume any of this is being handled automatically, whether by your own systems or by a vendor.
The properties that exit the second half of the year successfully will be those that have a clear, documented plan in hand today, with named owners for each compliance area and a realistic timeline for closing any gaps before the 2027 filing season opens.