IRS TIN Matching page; Creating an account for IRS.gov; Publication 5717 (Rev. 9-2026); Foreign Filer TCC Registration page and FAQs; IRS e-file application tutorials.
The rule underneath: one verified person per login
IRS online services do not issue logins to companies. Each person signs in with their own credential from a credential service provider, which verifies who they are. The IRS manual lists e-Services, including TIN Matching and the applications for Transmitter Control Codes, among the tools reached this way: “The following IRS tools are accessed through the SADI registration and login process” (IRM 21.2.1.58, Secure Access Digital Identity, 06-12-2026).
Verification needs a U.S. number. The IRS's account help page says that to verify your identity with ID.me you need “A Social Security number (SSN) or individual taxpayer identification number (ITIN)” and a government photo ID. Its explanation of ID.me error code 6101, which appears when someone verified without one, is blunt: “The IRS currently requires one of these to access IRS accounts and services” (Creating an account for IRS.gov, reviewed August 18, 2026). Living abroad is not the problem; the same page has help for people who live outside the U.S. and have an SSN, and for ITIN holders. Having neither is.
Sharing one person's IRS login with a team is not a workaround. Each user accepts the e-Services terms of agreement when signing in, and the credential is tied to that person's verified identity.
System by system
| IRS system | Who signs in | SSN or ITIN needed | If nobody has one |
|---|---|---|---|
| e-Services TIN Matching (interactive and bulk) | Each user, with their own IRS account | Yes, for identity verification | No separate IRS route published; the work is done by a verified U.S. user or by an authorized agent |
| IRIS Application for TCC (Taxpayer Portal and A2A) | Responsible Official, Contacts and Authorized Delegates | Yes, listed on the application | Foreign Filer TCC, filing through IDES |
| Foreign Filer TCC Registration System | Responsible Officer and up to five points of contact, through Login.gov or ID.me | No: only for filers whose users have neither | This is the route |
| Form 1042 through MeF | Responsible Official on the e-file application | SSN or ITIN | A foreign EFIN held by a U.S. provider in the business-related group |
| FIRE | Retired after the 2026 filing season; information returns go to IRIS. | ||
TIN Matching with a team abroad
The IRS's TIN Matching page sets three conditions. Who may use it: “TIN Matching is only for payers and their authorized agents that submit information returns.” Which payers: “To use this service, a payer must be listed in the IRS Payer Account File (PAF) database.” And how: “To apply for and use the TIN Matching service, you'll need an IRS account” (Taxpayer Identification Number (TIN) Matching, reviewed August 10, 2026). Nothing on the page or in the manual limits where the payer's staff work, but every person who signs in needs that verified IRS account, and the IRS publishes no foreign-user route for TIN Matching the way it now does for IRIS.
In practice a payer with an AP team abroad has three options:
- A verified U.S. user runs the matches. Someone in the U.S. with an IRS account submits the names and TINs the team collects, interactively (up to 25 per request) or as a bulk file. It works and it becomes a queue at onboarding peaks.
- Staff who already hold an ITIN or SSN sign in themselves. A team member abroad who has either number can verify with ID.me and be added as a user on the payer's TIN Matching account.
- An authorized agent runs the matching. The IRS page names authorized agents alongside payers. A service provider acting as the payer's agent submits the matches, and the payer's staff, wherever they are, work in the provider's system rather than in e-Services.
How TIN Matching itself works, the result codes and the bulk file are in the TIN Matching guide.
IRIS: who must hold an SSN or ITIN
Every transmitter needs an IRIS TCC, and each person on the application signs in: “Each user is required to create an account or sign-in using their existing credentials to validate their identities using the latest authentication process” (Publication 5717, section 2.1). The application asks for the firm's EIN (“the system doesn't allow firms to use a Social Security Number (SSN) or Individual Taxpayer Identification Number (ITIN)”) and, for each person in the role of Responsible Official, Contact and Authorized Delegate, an SSN or ITIN and date of birth (section 2.2). A Responsible Official signs the application with a five-digit PIN, and the IRS allows up to 45 days to process it. The TCC lifecycle, including changes of Responsible Official, is in the TCC guide.
The IRS has acknowledged the gap. Its May 4, 2026 e-News for Withholding Agents said these requirements “create a significant barrier for certain foreign filers, who may be unable to obtain an SSN or ITIN for their authorized users and therefore cannot complete the authentication process necessary to apply for or maintain a Transmitter Control Code (TCC)”, and that such filers “may be forced to rely on third-party intermediaries or face challenges in meeting their filing obligations” (e-News for Withholding Agents, Issue 2026-04). Publication 5717 (Rev. 9-2026) now says: “The IRS deployed the Foreign Filer TCC Registration System for foreign filers who are unable to obtain or maintain a TCC.”
The Foreign Filer TCC and IDES
Who it is for, in the IRS's words: “Only foreign filers with authorized users (individual persons) who do not have a Social Security number (SSN) or individual taxpayer identification number (ITIN) and therefore are unable to obtain or maintain a Transmitter Control Code (TCC) that is required to submit information returns through the Information Return Intake System (IRIS)” (Foreign Filer TCC Registration, reviewed October 14, 2026). Who it is not for: “Filers with authorized users that have a U.S. taxpayer identification number, such as an SSN or ITIN, must not use the new Foreign Filer TCC Registration System.” If even one person on your team has an SSN or ITIN, the IRS expects you to use IRIS.
How it works, from the registration page, the FAQs and Publications 6167 (quick steps) and 6170 (user guide):
- Sign-in. “Each authorized user will be required to create or sign in to a Login.gov or ID.me account”. The system then issues a six-character Foreign Filer ID used to identify the account.
- Legal name. “The legal name entered during registration must exactly match the legal name used when the Employer Identification Number (EIN) was obtained”. The registration needs the firm's EIN; a mismatch returns an error.
- People. One Responsible Officer, who receives every notification email and “must also serve as the International Data Exchange Service (IDES) Account Administrator”, plus up to five points of contact. “Only one user can log in to the account at a time.”
- What you get. A TCC Global Intermediary Identification Number (TCC GIIN) and a TCC, used to enroll in IDES and transmit Forms 1042-S, applicable Forms 1099 and other information returns.
- Several entities. A Responsible Officer filing for several entities can use one TCC GIIN and TCC; each entity does not need its own.
- Not interchangeable. A FIRE or IRIS TCC cannot be used in IDES, and a Foreign Filer TCC is not an IRIS TCC: “The TCC is system-specific and is not interchangeable between FIRE, IRIS, and IDES.”
Form 1042 is different
The Foreign Filer TCC covers information returns, not the annual Form 1042 return: “The International Data Exchange Service (IDES) cannot be used to electronically file Form 1042”, which must be filed through Modernized e-File. A foreign withholding agent whose officers have neither an SSN nor an ITIN can use the foreign EFIN route, where a U.S. firm in its business-related group that is an authorized e-file provider holds the EFIN, or a provider that files for it. The three routes are set out in getting an EFIN to e-file Form 1042.
Common setups
| Situation | What usually works |
|---|---|
| U.S. company, AP or vendor onboarding team in Mexico, India, the Philippines or Costa Rica | The U.S. entity stays the filer and owns its IRIS TCC through U.S. officers. TIN Matching runs through U.S. users or an authorized agent; offshore staff collect W-9s and work the results. |
| Accounting firm or outsourcer whose delivery center prepares clients' 1099s | The firm's U.S. Responsible Officials hold the transmitter TCC. As an authorized agent, match only for the clients whose returns you prepare, and keep each client's results separate. |
| Foreign company that must file 1042-S or 1099s and has no one with an SSN or ITIN | Foreign Filer TCC and IDES for the information returns; the foreign EFIN route or a provider for Form 1042. |
| Foreign company with one U.S. employee who has an SSN | IRIS, not the Foreign Filer TCC: the IRS says filers with any authorized user holding an SSN or ITIN must not use it. |
What does not change
- The payer is still the filer. Penalty notices such as the CP2100 and Notice 972CG go to the payer, whoever did the work (CP2100 and B-Notices, Notice 972CG).
- TIN Matching is for information returns. The IRS limits it to payers and their agents that submit information returns; it is not a general way to look up vendors.
- Access follows the person. When a Responsible Official or user leaves, update the IRIS application (some changes require every Responsible Official to re-sign, Publication 5717 section 2.2.3) and remove their access to any system that holds your payees' TINs.
- Data transfer is your call. Moving U.S. payees' names and TINs to staff abroad is a matter for your own privacy and security policy; the IRS pages above do not address it.
Questions people ask
Can someone outside the U.S. use IRS TIN Matching?
If they have an SSN or ITIN and can verify an IRS account, yes: the IRS page limits TIN Matching by who the payer is, not where its staff sit. Someone with neither cannot create the IRS account the service requires, and the IRS has not published a separate route for them.
Can we get our offshore staff ITINs so they can sign in?
An ITIN is applied for on Form W-7 for a federal tax purpose; the IRS pages on account access do not offer it as a way to get system access. Check the Form W-7 instructions before relying on this.
We have one U.S. officer and a team abroad. Can we use the Foreign Filer TCC?
No. The IRS says filers with authorized users that have an SSN or ITIN must not use it and must apply for an IRIS TCC instead.
Does the Foreign Filer TCC let us file in IRIS?
No. It is used to transmit through IDES. The IRS says the TCC is system-specific and not interchangeable between FIRE, IRIS and IDES.
Can a foreign filer e-file Form 1042 through IDES?
No. Form 1042 goes through Modernized e-File. Foreign filers without an SSN or ITIN use a foreign EFIN held by a related U.S. provider, or a provider that files for them.
Is it acceptable for an outsourcer abroad to do our 1099 work?
The IRS rules on these pages are about who can sign in, not where the work is done. The payer remains responsible for the returns, the TINs and any penalties.