IRS-Direct 1099-R and 1099 Filing for Insurance Carriers

Morado is a fully certified IRIS A2A transmitter filing 1099-R, 1099-NEC, 1099-MISC, and 1099-INT directly to the IRS through IRIS under its own production TCC. Morado supports the full information return series. You file under Morado's TCC, your team keeps the process in-house, and average processing time is under 10 minutes for 50,000 forms.

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Four systems, one filing obligation

A carrier's information returns come from every corner of the company. The policy admin side generates the volume, the distribution and claims sides generate the variety, and in January it all has to leave the building as one clean filing.

Around that core, the rest of the series is supported too: 1099-LTC for long-term care and accelerated death benefit payments, 1099-SB for reportable policy sales, 1099-DIV and the rest of the 1099 family, and 1042-S for payments to foreign policyholders and beneficiaries.

Two boundaries worth stating plainly. Most claim payments to claimants, property damage and personal physical injury, are not reportable at all; the reportable claims-side money clusters around attorneys, taxable settlement components, and interest. And ACA coverage reporting (1095-B, 1095-C) files through the IRS AIR system, not IRIS, so it is outside this transition entirely.

Your year-end tax extract was built for FIRE

The year-end routine at a carrier has looked the same for decades. The admin system runs its tax cycle, the cycle writes a tax reporting extract, usually already in IRS Publication 1220 format, and someone uploads it to FIRE and saves the receipt. The distribution codes in Box 7, the gain calculations, the withholding amounts: all of that work happens upstream, in the system your teams already trust.

That routine is ending. FIRE's last filing day is November 19, 2026, at 3 p.m. ET, and after January 1, 2027 IRIS will be the only IRS e-file system for information returns, including corrections and prior-year filings (IRS FIRE page).

Here is the part that matters: the extract your systems produce does not have to change. The system that accepts it does. FIRE took fixed-width Pub 1220 records. IRIS takes XML and validates every record at intake.

Start from the extract your systems already write

Morado ingests what your systems export. If it writes a Pub 1220 file, an XLSX, or a CSV, it is a source, and spreadsheet mappings are reviewed and confirmed by your team before anything moves.

Life and annuity policy admin, commercial, mainframe, or homegrown:

• DXC VANTAGE-ONE, CyberLife, and wmA
• Oracle OIPA
• Accenture Life Insurance & Annuity Platform (ALIP)
• Verisk FAST, Majesco, and Sapiens CoreSuite
• EXL LifePRO and Infosys McCamish VPAS
• The mainframe application your team has run for thirty years

TPA-administered blocks. If Zinnia (formerly SE2), Infosys McCamish, DXC, or another administrator runs a block of your business, Morado ingests the tax extract your TPA produces. The administrator keeps administering; your team keeps filing.

P&C claims and disbursement. Year-end extracts from Guidewire ClaimCenter, Duck Creek, and claims payment platforms like One Inc, VPay, and Snapsheet, alongside vendor 1099 data out of SAP, Oracle, or Workday AP.

Commission systems. The year-end producer file from Varicent, SAP Commissions, VUE, Vertafore Sircon, or the homegrown compensation system, with W-9 data from producer onboarding.

These are sources Morado reads, not integrations you build. No re-keying, no vendor template, no rebuild of the tax cycle your team already runs.

Many blocks, many EINs, one filing season

Most carriers run more than one admin system. Acquisitions leave blocks behind on the systems they arrived on, reinsurance deals move business without moving platforms, and a closed block can sit on a mainframe for decades because converting it is riskier than running it. Year-end then means multiple extracts, in multiple layouts, sometimes produced by multiple administrators, feeding one filing obligation.

Morado consolidates them. Each source file is ingested, validated, and filed through one pipeline, and multi-entity filing is fully supported: multiple payer EINs, writing companies, and acquired blocks in one season, with per-payer configuration and per-batch audit artifacts. The filing calendar stops caring how many systems January's data came from.

What filing through IRIS yourself would take

IRIS is not FIRE with a new login. Filing through the IRIS A2A channel directly means your company builds and maintains:

• An IRIS TCC. FIRE TCCs do not carry over. An IRIS TCC takes up to 45 days.
• ID.me identity proofing for each responsible official on the application. Individual staff members verify their personal identity through a third-party service.
• X.509 certificates and JWKS key hosting for A2A authentication.
• OAuth2 and mTLS connectivity to the IRS transmission endpoint.
• The IRIS XML schema. Fixed-width Pub 1220 records become nested XML, and the IRS publishes a new schema version every year.
• ATS testing. The IRS assurance testing cycle, repeated annually before production filing.

Each of those is an IT project, a security review, or a procurement cycle. Several are all three.

The free alternative is the IRIS Taxpayer Portal, which caps CSV uploads at 250 records per file (PY2026), with corrections keyed manually. Against a six-figure 1099-R run, that is not a path.

Morado is the third option. You file under Morado's production transmitter TCC. You skip: the TCC application · ID.me proofing · X.509/JWKS cert setup · annual ATS testing. Nobody on your staff proofs their identity through ID.me, hosts a certificate, or sits an IRS testing cycle.

Replacing the software or service you file with today

Carriers reach January in one of three postures: a tax information reporting service like Sovos, a desktop package like 1099 Pro Enterprise or Account Ability driving a FIRE upload, or an in-house process built on the company's own FIRE TCC.

Morado replaces all three head-on, end to end: ingestion, validation, IRS transmission, corrections, recipient copies, and the audit trail, in one pipeline your team operates. If you file on your own FIRE TCC today, the switch is smaller than it looks. Your extract stays the same, and the credentialing burden moves to Morado. White-glove migration is included when you file with Morado.

Validation before anything transmits

FIRE checked file format. IRIS checks the contents of every record and rejects at intake.

Morado runs the same rules first, before the IRS sees anything. Every batch is validated against the IRS schema (TIN formatting, address character classes, dollar amount precision) and the IRIS business rules (recipient account uniqueness, payee name controls, transmitter and issuer separation), with real-time TIN validation against IRS records during processing. Issues surface in a report your team can open in Excel, fix at the source, and re-run.

Carrier files carry exactly the history where problems hide: policies written decades before anyone validated a TIN, estates and beneficiary records from death claims, name changes across a fifty-year contract, producer W-9s collected at appointment and never touched again. Preflight surfaces those issues in your office in December, not as IRS rejections or CP2100 B-notices later.

Withholding stays your process. W-4P and W-4R elections, backup withholding, and the Form 945 reconciliation live where they live today; Morado carries the withholding amounts your systems computed onto the filed returns, consistent between the IRS file and the recipient copies.

Corrections, fully in-house

Carrier corrections have their own calendar. A Box 7 distribution code recoded after a claims review. A taxable amount amended when a gain calculation is corrected. A 1099-R reissued to an estate. A producer's commission total adjusted after chargebacks.

Morado files corrections through the same IRIS A2A pipeline as originals, with the same validation and the same audit artifacts. Fix the record, and Morado transmits the correction. No separate portal, no manual re-keying.

New for TY2026: the $2,000 threshold

For tax years beginning after 2025, the reporting threshold for most 1099-NEC and 1099-MISC payments rises from $600 to $2,000 under P.L. 119-21, with inflation indexing beginning in 2027. Two carve-outs matter to carriers: gross proceeds paid to an attorney in Box 10 stay reportable at $600, and royalties stay at $10 (IRS Instructions for Forms 1099-MISC and 1099-NEC, Rev. December 2026).

The calendar itself does not move: recipient copies by January 31, 1099-NEC filed by January 31, the rest of the IRS e-file by March 31, and 5498 by May 31. Morado's validation applies the current-year thresholds and instructions, so a season of rule changes lands on Morado's side of the work.

Security your vendor-risk team can walk through

An insurer's filing data is a roster of policyholders, Social Security numbers, and dollar amounts: NPI under the state privacy rules that implement GLBA for carriers. The vendor-oversight requirements are explicit, from NYDFS 23 NYCRR Part 500's third-party service provider provisions to the NAIC Insurance Data Security Model Law adopted across half the states, to the Model Audit Rule's control expectations and what a market conduct exam expects you to produce. And the risk is not hypothetical: a 2023 ransomware breach at a major policy-administration BPO exposed personal data on more than six million policyholders.

Morado runs two ways, so where the data lives is your call.

BYOC (bring your own cloud). Morado deploys inside your own cloud environment. Your data never leaves your cloud. For your security review, the data-flow diagram ends at the perimeter your examiners already scoped.

Managed. A dedicated, isolated environment operated by Morado.

Both carry the same audit spine. Per batch, six artifacts: the original workbook, canonical JSON, payer configuration, transmitted XML, the IRS submission acknowledgment, and the IRS status response, retained at a stable path. Per action, a user-level trail: who uploaded, who approved, who transmitted, and when, with self-serve export and role-based separation of who can prepare, approve, and transmit. DOI exam ready, internal audit ready, policyholder dispute ready.

Policyholder copies, delivered

Every filing generates recipient Copy B PDFs. Annuitants and beneficiaries still expect paper tax packages in January, so Morado prints and mails, or delivers through a secure portal, or both. Same pipeline, same audit trail as the IRS side.

State filing pass-through

Annuity distributions carry state withholding, and most states still accept Publication 1220 format for state information return filings while the IRS moves to IRIS XML. Morado files through the Combined Federal/State Filing (CF/SF) program where applicable and exports state-ready Pub 1220 files for direct filing outside it. One upload, both formats.

Proof at production volume

Morado's production track record at six-figure, single-season volume is documented end to end in the casino case study: the preflight findings, the batch cadence, the IRS acknowledgments.

Read the full case study →

(Different industry, same pipeline. Volume and rigor translate.)

How pricing works

Seasonal pricing by volume tier, quoted up front. You know the season's cost before you file, which is the number a filing budget needs.

Who Morado works for

• Life and annuity carriers, from Fortune-scale mutuals to regional and fraternal carriers, filing 1099-R at block scale
• P&C carriers filing 1099-NEC and 1099-MISC out of claims, AP, and the producer force
• Health carriers filing 1099-NEC, 1099-MISC, and 1099-INT (ACA reporting stays on AIR and is unaffected)
• Runoff and reinsurance consolidators filing for acquired blocks spread across inherited admin systems
• Carriers with TPA-administered blocks who want the filing function in-house even where administration is not
• TPAs and BPO administrators filing on carriers' behalf
• Carriers with their own FIRE TCC today whose credential does not carry over to IRIS

How it works

1. Upload your data. The Pub 1220 tax extract from your admin system or TPA, the commission system's year-end file, claims and AP exports, XLSX or CSV.
2. Confirm the mappings. Morado proposes the mapping; your team reviews, confirms, or overrides before anything moves.
3. Review the preflight report. Every schema and business rule issue, fixable in Excel, before transmission.
4. Morado transmits under its production TCC. Directly to the IRS through IRIS A2A over mTLS, for every payer EIN in the group.
5. Artifacts land in your audit trail. Acknowledgments, status responses, and policyholder copies, retained at a stable path.

See Morado against your January volume

30 minutes with a Morado engineer. Walk through the pipeline against a sample of your real filing data, anonymized if you prefer.

Book a demo →

Frequently asked questions

Which forms do insurance carriers file through IRIS? The core carrier stack is 1099-R for annuity and pension distributions, 1099-NEC for producer commissions, 1099-MISC for attorney gross proceeds and taxable settlement components, 1099-INT for delayed death-claim interest and funds left on deposit, and 5498 for IRA-funded annuities. Morado supports the full information return series, including 1099-LTC and 1099-SB. ACA forms are separate: 1095-B and 1095-C file through the IRS AIR system, not IRIS.

Can we keep filing 1099-R in-house after FIRE retires? Yes. FIRE's last filing day is November 19, 2026, and after January 1, 2027 IRIS will be the only IRS e-file system for information returns. Morado transmits your returns directly to the IRS through IRIS A2A under its own production TCC, so your team keeps the filing function, the files, and the process in-house.

Can Morado ingest the Pub 1220 file our admin system or TPA produces? Yes. If your policy administration system, or the TPA administering a block of your business, writes a Publication 1220 file, Morado ingests it directly, validates it against the IRIS rules, and transmits it through IRIS A2A. Your year-end tax extract does not change. XLSX and CSV exports work too, with mappings your team reviews and confirms.

Do you handle agent-commission 1099-NEC volume? Yes. Commissions and overrides to independent producers file as 1099-NEC, and carriers with large agent forces produce tens of thousands of them. Morado ingests your commission system's year-end file, validates every producer TIN against IRS records before filing, and transmits through IRIS A2A alongside the rest of your form stack.

Does IRIS cover 1095-B and 1095-C? No. ACA information returns, 1095-B for coverage issuers and 1095-C for applicable large employers, file through the IRS AIR system, a separate platform with its own TCC and its own XML schemas. The FIRE retirement does not move them. IRIS covers the 1099 series, W-2G, the 1098 series, and 5498, and that is the scope Morado files for carriers.

We file on our own FIRE TCC today. Does it carry over to IRIS? No. FIRE TCCs do not carry over, and a new IRIS TCC application takes up to 45 days plus ID.me proofing for each responsible official. Filing under Morado's TCC removes that entire track.

Do our staff need ID.me accounts to file through Morado? No. You file under Morado's production transmitter TCC. You skip: the TCC application · ID.me proofing · X.509/JWKS cert setup · annual ATS testing. Nobody on your staff verifies their identity through ID.me or manages IRS credentials.

How does BYOC work for a regulated carrier? BYOC deployment runs Morado inside your own cloud environment, so your data never leaves your cloud and the data-flow diagram ends at the perimeter your examiners already scoped. The alternative is a dedicated, isolated environment operated by Morado. Either way, every action is attributed: who uploaded, who approved, who transmitted, and when, with self-serve export for vendor-oversight files.

Does Morado support 1099-LTC and 1099-SB? Yes. Morado supports the full information return series, including 1099-LTC for long-term care and accelerated death benefit payments and 1099-SB for reportable life insurance policy sales. They run through the same ingestion, validation, and IRIS A2A transmission pipeline as the rest of your form stack.

Can we file for multiple subsidiaries and payer EINs? Yes, fully supported. Carriers file under many legal entities: writing companies, acquired blocks, fronting arrangements. Morado handles multiple payers in one filing season through one pipeline, with per-payer configuration and per-batch audit artifacts, so a multi-entity group files everything in one place.

What changed for TY2026 reporting thresholds? For tax years beginning after 2025, the reporting threshold for most 1099-NEC and 1099-MISC payments rises from $600 to $2,000 under P.L. 119-21, with inflation indexing beginning in 2027. Gross proceeds paid to an attorney in Box 10 stay at $600, and royalties stay at $10, per the IRS Instructions for Forms 1099-MISC and 1099-NEC (Rev. December 2026).

How do corrections work after year-end? Corrected returns file through the same IRIS A2A pipeline as originals, with the same validation and audit artifacts. A corrected Box 7 distribution code, an amended taxable amount after a gain recalculation, a reissue to an estate, or an adjusted commission total after chargebacks all follow the same fix-and-retransmit path, in-house.

What about state withholding and state filing? Morado files through the Combined Federal/State Filing (CF/SF) program, so eligible forms reach participating states with your federal filing. For states and forms outside CF/SF, Morado exports state-ready Pub 1220 files for direct filing. Annuity distributions carry state withholding; one upload covers the federal file and the state formats.

How much volume can Morado handle for a carrier? Morado is built for teams filing 1,000 to 1,000,000+ information returns a season. A mid-size annuity block produces tens of thousands of 1099-Rs; the largest carriers run hundreds of thousands to millions of recipient forms. For the TY2026 season, Morado is on track to file over 2 million information returns across credit unions, universities, public pension systems, and casinos. Read the full transition guide →