Are we REQUIRED to use IRIS system for 1099-R filing for clients?

I am SO confused by this, and cannot find answers. 

I am a TPA, and I have about 15 clients that had participant distributions from their plans during 2024.  That's 15 separate plan-sponsors.  I use Datair - I input each individual's 1099-R data, and print the 1099-R for the participant and the plan's copies.  Then I move on to the next sponsor.  I do this on paper forms that I order, and feed into my printer as I print each 1099-R.

Am I now required to use the IRIS system??  Or can I keep on doing it the way I've done it -- print XYZ's 401(k) Plan's 1099-Rs, then print ABC's 401(k) Plan's 1099-Rs, and so on?

Thanks!  Trying to be as clear wtih my question as possible.  I appreciate any answer, even if it's fussing at me for being so dense 🫣

General Instructions for Certain Information Returns (2024)
(Forms 1096, 1097, 1098, 1099, 3921, 3922, 5498, and W-2G)

https://www.irs.gov/instructions/i1099gi

Quote

E-filing returns.

 

The Taxpayer First Act of 2019 authorized the Department of the Treasury and the IRS to issue regulations that reduce the 250-return e-file threshold. T.D. 9972, published February 23, 2023, lowered the e-file threshold to 10 (calculated by aggregating all information returns), effective for information returns required to be filed on or after January 1, 2024. Go to IRS.gov/InfoReturn for e-file options.

Quote

Who must e-file.

 

If you are required to file 10 or more information returns during the year, you must e-file. The 10-or-more requirement does not apply separately to each type of form. For example, if you must file four Forms 1098 and six Forms 1099-A, you must e-file.

The e-file requirement does not apply if you apply for and receive a hardship waiver. See How to request a waiver from e-filing , later.

In short, if the sponsor is required to file 10 or more information returns during the year, then they must e-file. This probably covers nearly every business in the US that has employees.

There are several companies that will electronically file 1099s as a service.  Pricing for small batches usually is a fixed fee per form.  A simple search for "1099 R filing service" will get you started.

Thank you CB and Paul.

CB - you hit on my question exactly - it's the sponsor who has more than 10 1099-Rs to file that has to use IRIS.  If I'm filing <10 1099-Rs per client, I as a TPA don't have to.  Is that right??  My assumption makes sense, but I don't want to screw up.

And by the way, my clients are very small employers, so there are rarely 10 distributions from a single sponsor's plan in a given year.  😁  Some don't even have 10 employees.

From the instruction quoted above:

“If you are required to file 10 or more information returns during the year, you must e-file.”

Consider exactly which person is the “you” in that sentence. Also:

“The 10-or-more requirement does not apply separately to each type of form. For example, if you must file four Forms 1098 and six Forms 1099-A, you must e-file.”

If the quoted instruction fairly describes the law, the measure is not about whether one files ten 1099-Rs; it’s about whether one files ten information returns, counting several kinds.

Consider that it might be impractical for a TPA to get from an employer or a plan’s administrator the total number of information returns it files. Or, that the count varies from year to year, with some years fewer than ten but other years with at least ten.

Thank you!  Yes, ok, the "you" is the sponsor/employer (in my case).  And thank you for pointing out that it's NOT just talking about 1 type of form, but ALL information returns. W-2s etc!  Yeah, better use IRIS 😄

I appreciate your dumbing it down for me.