Your loan software tracks the interest. Your team has the numbers. But the question most lenders are asking right now is not how to calculate what goes on the report. It is how to actually get Form 1098-VLI to the IRS electronically and confirm it was received.
That is where the IRIS platform comes in. For lenders filing vehicle loan interest statements under the One Big Beautiful Bill Act, IRIS is the IRS's designated free tool for electronic submission. It is also the only option once the IRS retires its older FIRE system after the 2026 filing season.
If your organization has not set up an IRIS account yet, this guide covers everything you need: what the platform is, who must use it, how to build your account from scratch, and how to submit without running into the most common errors.
What Is the IRS IRIS Platform?
IRIS stands for Information Returns Intake System. It is a free, web-based portal the IRS built to replace the FIRE system, which has been running since 1996 on outdated flat-file technology.
IRIS accepts filings in three ways:
- Manual entry through the Taxpayer Portal - You type return data directly into the portal's form screens. This works well for lenders filing a small number of returns each year.
- CSV file upload - You download a template from your IRIS dashboard, fill it in, and upload the completed file. Each CSV holds up to 100 records.
- Application to Application (A2A) - Your internal software connects directly to IRIS through an XML-based API. This method suits lenders processing large volumes.
IRIS also validates your submission in real time. The old FIRE system often sent back error codes days after you submitted, through a separate download process. IRIS flags problems during the upload itself, so you can fix them before they become a compliance issue.
For a full breakdown of what lenders must report on vehicle loans, see our IRS car loan interest reporting guide (/blog/irs-car-loan-interest-reporting).
Who Must Use IRIS to File 1098-VLI?
Any commercial lender receiving $600 or more in interest from a single borrower on a specified passenger vehicle loan (SPVL) during the calendar year must file Form 1098-VLI. This includes:
- Banks and credit unions that originate or service qualified passenger vehicle loans
- Auto dealerships that provide direct financing to buyers
- Finance companies that hold or service SPVLs
- Any business receiving SPVL interest in the course of trade or business, even if lending is not the primary activity
The $600 threshold applies separately to each loan, not to a borrower's combined payments across multiple loans. If one borrower holds two SPVLs with your organization and pays $400 in interest on each, neither loan triggers a filing requirement on its own.
On the e-file rule: if you file 10 or more information returns in total across all form types for the year, federal law requires electronic filing. Paper filing is only available to lenders submitting fewer than 10 returns across their entire reporting portfolio. For most commercial lenders, IRIS is not optional - it is the required channel.
The 2025 transition period: The IRS issued Notice 2025-57 granting penalty relief for tax year 2025. Lenders who made interest statements available to borrowers through a portal, monthly statement, or annual letter satisfied their obligations for that year. Full Form 1098-VLI electronic filing requirements - including submission through IRIS - take effect starting with tax year 2026 returns, due in early 2027.
Step-by-Step: Setting Up Your IRIS Account
Before you submit a single Form 1098-VLI, you need an active IRIS account and a Transmitter Control Code (TCC). The TCC is the credential that authorizes your organization to submit files to the IRS. Here is how to get one:
-
Create an IRS e-Services account. Go to the IRS e-Services portal on IRS.gov. Click Register and enter the Responsible Official's personal information - name, Social Security Number, date of birth, email, and mailing address. This account belongs to the individual, not the organization. An identity verification step through ID.me is part of the registration process.
-
Apply for an IRIS TCC. Once your e-Services account is active, go to the IR Application for TCC section. Select IRIS as your filing method, not FIRE. Complete the application with your organization's legal name, EIN, and the Responsible Official's details. You will also indicate whether you are filing as an issuer (your own returns) or a transmitter (filing on behalf of others).
-
Wait for TCC approval. The IRS typically processes TCC applications within 24 hours. The official window extends up to 45 days during peak periods. Your TCC will arrive by email. Do not wait until your filing deadline to apply - start this process at least 60 days before you need to file.
-
Log in to the IRIS Taxpayer Portal. With your TCC confirmed, go to iris.irs.gov and sign in using your e-Services credentials. Your dashboard shows the forms available to file, your submission history, and CSV template downloads.
-
Complete assurance testing if you are using A2A. Lenders using the Application to Application method must pass the IRIS Assurance Testing System (ATS) before submitting live returns. This is a required one-time communication test for all A2A transmitters. Portal and CSV filers do not need to complete ATS.
How to Submit Form 1098-VLI Through IRIS
Once your account is ready, the submission process follows a clear path. The steps below apply to the CSV upload method, which works well for most lenders. Portal entry follows the same logic in a guided form interface.
-
Download the 1098-VLI CSV template. Log in to the IRIS portal and click Upload CSV with Form Data on your dashboard. Select Form 1098-VLI from the form type list and download the template for the applicable tax year. The template includes a column header for every required field.
-
Fill in the borrower data. Each row is one Form 1098-VLI. Required fields include the borrower's name, address, and Tax Identification Number (TIN); the total vehicle loan interest received in Box 1; vehicle year, make, model, and VIN in Boxes 2a through 2d; the outstanding principal balance as of January 1 in Box 3; the loan origination date in Box 4; and any refund of overpaid interest in Box 5. Format dollar amounts as plain decimals - 1825.50, not $1,825.50. Format dates in MM/DD/YYYY.
-
Upload the completed CSV. Return to the Upload CSV page, select your file, and submit. IRIS validates against its schema in real time. If any row fails validation, the portal returns a specific error message with the field name and record number.
-
Check your submission status. IRIS assigns a status to each transmission within 48 hours. Log in and check Submission History on your dashboard. The four status types are explained in the next section.
-
Send borrower copies separately. Submitting to IRIS covers your IRS filing obligation. You must also send Copy B of Form 1098-VLI to each borrower by January 31 of the year following the reporting year. IRIS does not send copies to borrowers - that step stays with you.
For a complete explanation of every field on the form, see our Form 1098-VLI line-by-line guide (/blog/form-1098-vli-line-by-line).
Common IRIS Errors on Form 1098-VLI and How to Fix Them
IRIS validates in real time and returns field-level messages during upload. That means faster feedback than the old FIRE system. It also means your data needs to be clean before it goes in.
These are the most common errors lenders run into when filing 1098-VLI:
- TIN mismatch (error code SMF018) - The borrower's TIN and name do not match IRS records. This causes an outright rejection. Check that the TIN on file matches the borrower's Social Security Administration records, not just your loan origination data. Transposed digits and abbreviated names are the most frequent causes.
- Missing phone number in issuer detail - IRIS requires a contact phone number for the filing organization. If this field is blank, the submission receives an "Accepted with Errors" status. Add the Responsible Official's phone number in your payer setup before submitting.
- XML schema validation errors (A2A filers only) - Element order matters in IRIS's schema. Amounts must be plain decimals with no commas. Dates must follow ISO 8601 format (YYYY-MM-DD). State codes must be two-letter abbreviations. One deviation rejects the entire transmission. Validate your XML against the official IRS XSD file before sending to production.
- VIN formatting errors - VINs must be exactly 17 characters. Spaces, hyphens, and lowercase letters all cause validation failures. Strip non-alphanumeric characters and convert to uppercase before filling the template.
- Dollar amount formatting - Interest amounts must be plain decimal numbers. The value 1825.50 is correct. The value $1,825.50 will fail. Review all Box 1 and Box 5 entries in your CSV before uploading.
- Trying to correct a FIRE-filed return through IRIS - IRIS and FIRE are separate systems. If a borrower's return was originally filed through FIRE, any correction must also go through FIRE. IRIS cannot access or change FIRE records.
Status Confirmations and Acceptance Notifications
After you submit, IRIS assigns one of four status levels to your transmission. Log in to your dashboard and check Submission History to see where your filing stands.
- Accepted - The IRS received and processed your return. No further action needed. IRIS confirms this status within 48 hours of submission.
- Accepted with Errors - Your return was accepted for processing, but specific records have issues - usually TIN mismatches or missing fields. These do not block processing, but they can trigger IRS CP2100 notices or penalty letters later. Review the error detail and file corrected returns for the affected rows.
- Partially Accepted - Some records in your submission were accepted and others were rejected. Check the submission record to identify which rows failed. Correct them and resubmit the rejected records as new original filings.
- Rejected - The entire transmission failed. This usually comes from an XML schema validation error or a TCC authentication problem. Rejected transmissions cannot be corrected using the Replacement function - fix the error and resubmit as a new original filing.
If your submission stays in pending status for more than 48 hours, check the IRS IRIS Known Issues page on IRS.gov. The IRS posts platform-wide processing delays there with resolution timelines.
For corrections to previously accepted returns, use the IRIS Correction workflow. You will need the Unique Record ID assigned to the original accepted form.
IRIS vs. Third-Party Filing Services: Which One Fits Your Needs?
IRIS is free and sends data directly to the IRS. Third-party services charge per form but handle the technical formatting and submission process for you. The right choice depends on your filing volume and how much time your team can put into data preparation.
| Factor | IRIS Direct | Third-Party Service |
|---|---|---|
| Cost | Free | $1 - $3 per form, with volume discounts |
| Data prep | Your team handles CSV formatting and schema rules | Service accepts your data in their own format |
| Error handling | Raw field-level error codes you must read and fix | Plain-language alerts; many auto-correct formatting issues |
| Speed | Manual entry takes more time per return | Bulk upload and validation is faster at high volume |
| Security | Runs on IRS infrastructure | Encrypted third-party systems; must meet IRS standards |
Smaller lenders filing under 100 Forms 1098-VLI per year will find IRIS direct filing practical and free. Lenders with higher volumes across multiple loan types often find the per-form cost of a service pays for itself in time saved and errors avoided.
Start the Account Process Now
Filing Form 1098-VLI through IRIS is not a one-day task. The TCC application alone can take up to 45 days. Add time for ID.me verification, assurance testing if you use A2A, and a clean review of your borrower data. Lenders who start in October or November have room to fix problems. Lenders who wait until December are already behind.
The steps that take the longest - account registration and TCC approval - both happen before you touch a single form. If your organization services qualified passenger vehicle loans and has not yet applied for an IRIS TCC, that is the first step to take today.
Start with your borrower data. Make sure your loan servicing records have complete 17-character VINs, TINs that match IRS records, and interest totals calculated correctly for each SPVL. A clean data file saves more time at the filing stage than anything else you can do.
Ready to track the latest IRS guidance on vehicle loan interest as the 2026 rules take full effect? Sign up for free updates (/sign-up) and we will send you what changes before it matters.
