Employers must prepare for Affordable Care Act (ACA) reporting covering the 2025 calendar year. Staying ahead of these deadlines is critical for Applicable Large Employers (ALEs) and providers of self-insured health plans.
Who is Required to Report?
Reporting obligations under Internal Revenue Code Sections 6055 and 6056 fall into two main categories:
- Self-Insured Health Plan Providers (Section 6055): Any entity providing minimum essential coverage (MEC), including non-ALEs with self-insured plans.
- Applicable Large Employers (ALEs) (Section 6056): Organizations with 50 or more full-time employees (including equivalents).
Note for Self-Insured ALEs: If you are an ALE with a self-funded plan, you must comply with both requirements. However, you can simplify the process by using a single combined filing (Forms 1094-C and 1095-C).
Important Filing Deadlines for 2026
| Action Item | Deadline |
| Provide Individual Statements (Directly to employees) | March 2, 2026 |
| Post Website Notice (Alternative to direct mailing) | March 2, 2026 |
| Electronic IRS Filing | March 31, 2026 |
| Notice Retention Period (If using the website option) | Until Oct. 15, 2026 |
How to Furnish Statements to Individuals
Employers have two options for providing Forms 1095-B or 1095-C to covered individuals:
- Direct Delivery: Automatically mail or electronically deliver the forms by March 2, 2026.
- Website Notice Alternative: Instead of mailing every form, you may post a “clear, conspicuous, and easily accessible” notice on your website by March 2, 2026.
- The notice must state that individuals can request a copy of their form.
- It must include an email address, physical address, and phone number for requests.
- Requests must be fulfilled within 30 days.
Mandatory Electronic Filing
The IRS now requires electronic filing for almost all employers.
- The 10-Return Threshold: If you file 10 or more information returns in total (including W-2s, 1099s, and ACA forms combined), you must file your ACA returns electronically.
- The System: Electronic filings must be submitted through the ACA Information Returns (AIR) Program using specific XML formatting.
Extensions and Hardships
- Automatic Extension: You can secure an additional 30 days to file with the IRS by submitting Form 8809 by the original March 31 deadline.
- Hardship Waivers: While the IRS encourages electronic filing for everyone, waivers may be available for those facing significant technological or financial hardships.