Is Your Team Ready for 1098-T Season? Here's Your Step-by-Step Guide.

When was the last time your 1098-T season ended without a late-January scramble? 

If the answer is "never," you're not alone. Over many 1098-T seasons, the thing I've seen cause the most stress isn't a technical mistake. It's waiting until the end of January, when there's no time left to test. This year the IRS is changing how institutions file, so I put together this guide to help your team get ahead of it, step by step.

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Step 1: Understand what's different this year

For years, institutions have filed their 1098-Ts electronically through the IRS's FIRE system. That system is being retired. The IRS lists November 19, 2026, at 3 p.m. ET as the last day to file information returns through FIRE. Starting with the 2027 filing season, the Information Returns Intake System (IRIS) will be the only way to file electronically.

Here's what that means for your team:

• You'll need a new TCC code. Filing through IRIS requires its own Transmitter Control Code (TCC). Your FIRE TCC won't carry over.
• Request it now. It can take up to 45 days to receive a new TCC, so apply for your IRIS TCC as early as you can. If you request it in mid-October, it should arrive by the end of November with room to spare. If you wait until January, you may not have it in time.
• This applies to almost everyone. Institutions with 10 or more information returns are required to file electronically, so for most schools, IRIS isn't optional.

You may see other dates on IRS pages for updating existing FIRE applications. To be safe, plan around November 19. For the full process, see the IRS guide to filing with IRIS.

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Step 2: Mark these dates on your calendar

• December 31, 2026: Deadline to make a good faith effort to collect any missing Social Security numbers or taxpayer identification numbers (SSN/TIN) from students. The IRS instructions for Form 1098-T explain what that effort involves.
• February 1, 2027: January 31 falls on a Sunday this year, so 1098-Ts sent by mail must be postmarked by February 1 at the latest.
• March 31, 2027: Your electronic 1098-T file is due to the IRS via IRIS.

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Step 3: Before December, get the pieces in place

• If you use a third party to process your 1098-Ts, confirm that the contract is in place and that you've agreed on a plan and a timeline.
• If you process in house, ask students early how they'd like to receive their form. Electronic delivery requires student consent, so the earlier you ask, the fewer forms you'll need to mail.
• Order your envelopes now. This is the item I see slip most often. By late January, every business is printing and mailing tax forms, and expediting an order costs money you didn't plan to spend.
• Review what you're telling students, including your website, and update anything that changed for the new year.

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Step 4: In January, test before you file

Testing is where a smooth season gets built. Focus on two things.

Check your codes. Any new charge, payment, or financial aid codes created during the year need to be mapped to the right boxes on the form. A code set up mid-year for a new fee or program is easy to miss, and a single unmapped code can affect every student it touches.

Test a wide range of student scenarios, including:

• Charges posted in 2026 for courses that start between January 1 and March 31, 2027
• Students living in campus housing
• Different student populations
• Different ways of paying: personal payments, financial aid (scholarships, grants, and loans), and third-party payments

A lesson learned: the hardest lesson I've learned came from a change the IRS made several years ago. Institutions used to report the amount charged during the calendar year, in Box 2. Starting with tax year 2018, they had to report payments received during the calendar year, in Box 1. Because schools typically bill for the spring term in December, a student can pay for spring classes in one tax year and attend them in the next. That crossover shows up on the form. Account for it when you review your calculations, and explain it to students before the questions start coming in.

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Step 5: Plan for the people, not just the forms

Much of the 1098-T process often lives in one or two people's heads. When the person who has always handled it moves on, someone new in Student Accounts inherits a process with tight deadlines and very little room for trial and error. A written timeline and a checklist like this one are often what keep the season on track. We wrote more about that kind of knowledge gap in Higher Ed's Real IT Shortage Isn't People. It's What They Take With Them.

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How Doctums can help

We don't produce 1098-T forms, and we're not tax experts. Where we help is the process around them. We work with institutions on an as-needed basis to set up and improve how 1098-T season runs, so it creates less anxiety year after year. That often means helping a new Student Accounts staff member work through the process for the first time, or reviewing setup before testing begins.

For questions about how specific amounts should be reported, the IRS guidance below and your tax advisors are the right place to go.

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Helpful resources

• IRS: About Form 1098-T
• NACUBO: IRS Form 1098-T resources
• IRS: E-file information returns with IRIS
• IRS: Instructions for Forms 1098-E and 1098-T

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If your team is heading into 1098-T season with someone new at the wheel, or you'd simply like the process to run more smoothly this year, we're glad to work through it with you.

Talk to our team.

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Written by Carol Suter, Senior Consultant, Doctums

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