--- title: ACA Returns Due Electronically by March 31, 2026 description: Most employers must now e file ACA returns because the IRS lowered the threshold to 10 forms, making electronic filing mandatory for nearly all. The deadline to file electronically is March 31, 2026. image: https://blog.nisbenefits.com/hubfs/blog-headers/aca-march-b.jpg --- ![calendar that reads March 31](https://blog.nisbenefits.com/hubfs/blog-headers/aca-march-b.jpg) # ACA Returns Due Electronically by March 31, 2026 - Home - [Employee Benefit News for School, City and County Employers](https://blog.nisbenefits.com) - ACA Returns Due Electronically by March 31, 2026 [ Steve Smith ](https://blog.nisbenefits.com/author/steve-smith) 02/17/2026 [ Health Insurance Solutions](https://blog.nisbenefits.com/topic/health-insurance-solutions), [ Legislative News](https://blog.nisbenefits.com/topic/aca-other-legislative-news), [ The Administrator's Corner](https://blog.nisbenefits.com/topic/the-administrators-corner) [0 Comments ](https://blog.nisbenefits.com/aca-returns-due-electronically-march-31-2026#postComment) 3 Minutes The Affordable Care Act (ACA) created reporting requirements under Internal Revenue Code Sections 6055 and 6056. These rules require certain employers to report to the IRS on the health coverage they offer/don’t offer to employees. Previously, entities filing 250 or more forms under Sections 6055 or 6056 had to file electronically. As of February 23, 2023, an IRS [final rule](https://www.federalregister.gov/documents/2023/02/23/2023-03710/electronic-filing-requirements-for-specified-returns-and-other-documents) lowered this threshold to 10 returns, meaning most reporting entities must now file ACA reports electronically.   ## **Action Steps** Employers subject to ACA reporting who have not requested an extension or electronic filing waiver should plan now for electronic filing to meet the March 31, 2026, deadline. Many will choose to partner with a third-party vendor for this process. Those prepared to file on their own can review the IRS’ [ACA Information Returns (AIR) Program page](https://www.irs.gov/e-file-providers/affordable-care-act-information-returns-air) for technical standards and submission requirements. For assistance with electronic filing issues, contact the IRS AIR Help Desk at 1-866-937-4130.   ## **Electronic Reporting Requirement** Previously, only entities filing at least 250 ACA statements under Sections 6055 or 6056had to file electronically, and this threshold applied separately to each form type. Now, employers filing 10 or more total information returns in a calendar year must file their ACA Forms 1094 and 1095 electronically, counted in aggregate with other returns such as Forms W‑2 and 1099. Electronic filing is currently done through the [AIR Program](https://www.irs.gov/e-file-providers/affordable-care-act-information-returns-air). While most of the IRS guidance for AIRis highly technical and geared toward software developers and service providers, it still offers helpful insight into the standards and procedures for transmitting returns. In practice, most employers and issuers work with a third‑party vendor to handle AIR electronic filing on their behalf.   ## **AIR Program Overview** The AIR Program is typically used by software developers, transmitters, and issuers. Most issuers, employers, and other reporting entities work with a third-party vendor to file electronically, so they do not usually use the AIR Program themselves.   ## **Electronic Reporting Process** The AIR Program requires the following for entities submitting electronic returns: - **Step One:** Register for IRS [e-Services](https://www.irs.gov/e-services) and, if you will be transmitting directly, apply for an [ACA Transmitter Control Code (TCC)](https://www.irs.gov/e-file-providers/air/apply-for-the-affordable-care-act-for-transmitter-control-code-tcc). Reporting entities that use a third-party vendor to file do not need a TCC. - **Step Two:** Complete required testing. Software developers must pass [ACA Assurance Testing System (AATS)](https://www.irs.gov/e-file-providers/air/affordable-care-act-assurance-testing-system-aats-information-returns) each year unless they previously passed for a tax year ending after December 31, 2014. Transmitters and issuers must use approved software to complete a one-time communications test. For more details, visit the IRS’ AIR Program main page.   ## **Waiver From Electronic Filing Requirement** A hardship waiver from the electronic filing requirement may be requested by submitting [Form8508](https://www.irs.gov/pub/irs-pdf/f8508.pdf), Application for Waiver from Electronic Filing of Information Returns, to the IRS. Reporting entities are encouraged to submit Form 8508 at least 45 days before, and no later than, the return due date. The IRS begins processing waiver requests on January 1 of the calendar year the returns are due. Per the Form 8508 instructions, a reporting entity’s first waiver request is automatically granted. For any subsequent request, the entity must include required cost estimates or a written statement supporting the need for a waiver. Examples include: - Undue financial hardship, where the cost of electronic filing exceeds the cost of filing on paper (must include two cost estimates comparing both methods). - A catastrophic event in a federally declared disaster area that prevents the business from resuming operations or accessing necessary records. - Fire, casualty, or natural disaster that disrupts business operations. - Death, serious illness, or unavoidable absence of the person responsible for filing information returns. - The business is in its first year of establishment. Waivers apply to only one tax year at a time, and entities must reapply each year a waiver is needed. Approved waivers are for the reporting entity’s records and should not be sent with paper returns. If a waiver is granted for original returns, it also covers corrections for the same return types. However, if original returns are filed electronically and the entity wants to file 10 or more corrections on paper, a separate waiver is required. Without an approved waiver, an entity required to file electronically that files on paper may be subject to a penalty of up to $340 per return (as adjusted annually), unless it can show reasonable cause. Reporting entities may file up to 10returns on paper without penalty for failure to file electronically.   ## **Filing Extension Requests** An automatic 30‑day filing extension can be requested by submitting Form 8809, *Application for Extension of Time To File Information Returns*, to the IRS on or before the original due date. No signature or explanation is required. [Form 8809](https://www.irs.gov/pub/irs-pdf/f8809.pdf) can be filed on paper or electronically through the [FIRE System](https://www.irs.gov/e-file-providers/filing-information-returns-electronically-fire). 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