Employers subject to Affordable Care Act (ACA) reporting under Internal Revenue Code Sections 6055 and 6056 should begin preparing now for early 2026 deadlines. For the 2025 calendar year, covered employers must:
- File ACA information returns with the IRS electronically by March 31, 2026. Electronic filing is required for employers submitting 10 or more returns in a calendar year.
- Post a clear, easily accessible notice on their website by March 2, 2026, informing individuals they may request a copy of Forms 1095-B or 1095-C. The notice must remain available through October 15, 2026, and statements must be furnished by no later than January 31, 2026, or 30 days after the request. Or employers can provide Forms 1095-B or 1095-C directly to individuals by March 2, 2026, without posting the online notice.
Covered Employers
The following employers must comply with ACA reporting requirements:
- Employers with self-insured health plans (Section 6055 reporting)
- Applicable Large Employers (ALEs) with fully insured or self-insured plans (Section 6056 reporting)
An ALE is an employer with 50 or more full-time (including full-time equivalent) employees in the previous calendar year. ALEs with self-funded plans must satisfy both reporting requirements, but the IRS allows them to use one combined form to report the information required under Sections 6055 and 6056.
Section 6055 and 6056 Reporting
Section 6055 applies to providers of minimum essential coverage (MEC), such as health insurance issuers and employers with self-insured health plans, who use Forms 1094‑B and 1095‑B to report the coverage they provided in the prior year.
Section 6056 applies to applicable ALEs with 50 or more full-time employees, including full-time equivalents who use Forms 1094‑C and 1095‑C to report the health coverage they offer (or do not offer) to full-time employees. ALEs with self-insured plans satisfy both 6055 and 6056 reporting by filing the combined Forms 1094‑C and 1095‑C.
Annual Filing Deadlines
Forms must be filed with the IRS each year by March 31 for the prior calendar year. Employers can request an automatic 30‑day extension by submitting Form 8809 by the original due date, and additional time may be available in certain hardship situations.
Individual Statements Upon Request
Under the original ACA reporting rules, employers had to automatically provide Forms 1095‑B and 1095‑C each year to individuals with minimum essential coverage and to all full-time employees. Now, employers can instead post a clear, easy-to-find notice on their website explaining that individuals may request a copy of their statement.
For 2025 statements furnished in 2026, the notice must:
- Include an email address, physical mailing address, and phone number for requests
- Be posted by March 2, 2026
- Remain available through October 15, 2026
Requests must be fulfilled by January 31 of the following year or within 30 days of the request, whichever is later. Employers may still choose to automatically furnish Forms 1095‑B and 1095‑C by March 2, 2026, and must continue to follow any applicable state reporting rules. Statements may also be provided electronically if the individual has given prior written consent and not revoked it.
Electronic Filing
For returns due on or after January 1, 2024, employers must file electronically if they submit 10 or more total information returns, counted in the aggregate (such as Forms 1094/1095, W‑2s, and 1099s). Even if you file fewer than 10 ACA forms, you may still be required to file electronically based on your total return count.
Employers that receive an approved hardship waiver are exempt from mandatory e‑filing, but the IRS still encourages electronic submission. Note that the paper form instructions are for print filing only, electronic submissions must follow the IRS “XML Schemas” and “Business Rules” on IRS.gov (see Publications 5164 and 5165).
ACA electronic filing is completed through the ACA Information Returns (AIR) Program. While AIR guidance is technical and geared toward software providers, it offers helpful details on standards and procedures for transmitting ACA returns.
Download the bulletin for more details.
Additional Resource
ACA Reporting Deadlines and Penalties Cheat Sheet
