How do I Submit Form 3921 Electronically Using Corporate Focus?

Section 6039 of the IRS code requires that Employers report any Exercise of an Incentive Stock Option using Form 3921 to both the individual participant and to the IRS. Both of these requirements can be fulfilled using Corporate Focus by using the Form 3921 – Substitute Participant Form and Form 3921 – Electronic Filing reports.

Outlined below are the IRS electronic filing requirements for Form 3921. Included are the steps to generate the file in Corporate Focus, as well information on where the eFile can be uploaded.

Before You Begin

Before you can generate or upload the eFile, you will need the following information on hand:

  • Your Company’s 9-digit Taxpayer Identification Number (TIN)
  • Your Company’s Transmitter Control Code (TCC)
  • An IRS FIRE System Account
    • All electronic file submissions for the IRS are submitted through the FIRE System
    • If you do not have an account you can create a new account at

Prepare the eFile in Corporate Focus

Once you have all of the required information, you can generate the eFile based on the data that has already been entered into Corporate Focus. To generate the eFile:

  1. Log into Corporate Focus and navigate to the Reports tab.
  2. Filter for Ownership reports and select the report Form 3921 – Electronic Filing and then click the View button.
  3. Set an Advanced Filter for Exercise/Cancellation > Date of Exercise. For 2012 filings, enter a date range of 1/1/2012 to 12/31/2012. NOTE:If you skip this step, you will receive exercises from pre-2012, so it is important that you set this filter.
  4. In the Parameters section, enter the required information for each parameter. All parameters are required before the eFile can be generated.
  5. Once the advanced filter and parameters are set, click the Preview button. This will display all records that will be included in the eFile.
  6. Click on the Export Electronic Filing button save the file. You will be prompted to save either a text (.txt) or a zip (.zip) file depending on the size.

Upload the eFile to the IRS

Once you export the eFile, you can upload it to the IRS directly using your FIRE System account at The IRS will notify you if there are any issues with your file submission.

For Uploading instructions, see the How to Upload Form 3921 to the FIRE System guide.


In the event that you need to submit corrections, please contact Two Step Software at 1-800-223-8900, press 2 for assistance.

Please note – Two Step Software will generate the corrected file based in the information provided by the customer and can assist with any software related questions. Two Step Software cannot validate the data that is provided, or make any recommendations on how to become compliant.

Additional Information

For more information on Form 3921 requirements, see the Corporate Focus Insight blog post on Section 6039 filing requirements.

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