ACA Reporting Requirements in 2026
By Brian Gilmore | Published November 12, 2025
Question: What are the ACA reporting deadlines and compliance requirements in 2026 to report on the 2025 calendar year?
Short Answer: ALEs must furnish the 2025 Forms 1095-C to employees no later than March 2, 2026. Alternatively, ALEs have a new option available to instead post an online notice of availability for employees to request their form. Regardless, ALEs must electronically file the Forms 1094-C and 1095-C with the IRS no later than March 31, 2026. Non-ALEs sponsoring a self-insured plan (including a level funded plan) face the same deadlines for the Forms 1094-B and 1095-B.
ACA Reporting: Overview
The ACA requires Applicable Large Employers (ALEs) to report whether they offered minimum essential coverage (MEC) that was affordable and provided minimum value to full-time employees. Employers sponsoring a self-insured plan (including level funded) must also report the months of coverage for all individuals. Regardless of funding arrangement, ACA reporting for ALEs is handled via IRS Forms 1094-C and 1095-C. In general, an employer is an ALE if it employed an average of at least 50 full-time employees, including full-time equivalent employees, on business days during the preceding calendar year.
Non-ALEs sponsoring a self-insured plan (including level funded) must report months of coverage for all individuals via IRS Forms 1094-B and 1095-B.
For more details: Newfront ACA Employer Mandate & ACA Reporting Guide
Final 2025 IRS ACA Reporting Forms and Instructions
The IRS recently finalized the forms and instructions for ALEs subject to ACA reporting at the start of 2026:
ACA Reporting Deadlines for ALEs
Updated ACA reporting regulations make permanent the 30-day automatic extension (from January 31) for employers to furnish the Form 1095-C to individuals. Accordingly, the ACA reporting deadlines for all ALEs in 2026 (regardless of plan year) are as follows:
Form 1095-C: Deadline to Furnish to Individuals
Due Date: March 2, 2026*
Form 1094-C (+Copies of Form 1095-C): Deadline to Electronically File with IRS
Due Date: March 31, 2026
Non-ALEs sponsoring a self-insured plan (including level funded) in 2025 face the same 2026 deadlines as above with respect to the Forms 1094-B and 1095-B.
*ACA Reporting No Longer Requires Furnishing of Forms 1095-C to All Full-Time Employees
At the end of last year, Congress passed the Paperwork Burden Reduction Act providing employers with a new option to significantly streamline the ACA reporting process. ALEs no longer have to furnish Forms 1095-C to all full-time employees. Instead, ALEs can choose to make the Forms 1095-C available upon request. This is referred to as a new “alternative manner of furnishing” Forms 1095-C. The option is particularly welcome given the high bar required for employers to furnish Forms 1095-C to employees electronically.
The same approach was already available for Forms 1095-B provided by insurance carriers and non-ALEs with self-insured health plans, previously referred to as the “§6055 furnishing relief.” The PBRA codified the relief for 1095-B purposes and—most significantly—extended it to the Forms 1095-C provided by ALEs.
To take advantage of this new “alternative manner of furnishing statements,” ALEs must:
Notice of Availability: Post on the employer’s benefits website by March 2, 2026 a clear, conspicuous, and accessible notice to employees that they may request a copy of the Form 1095-C; and
Provision Upon Request: If the employee requests a copy, the employer must provide a copy by the later of a) January 31, or b) 30 days after the date of the request.
The notice of availability posted on the website must be written in plain, non-technical terms using a font size large enough and any visual clues or graphical features to call attention to the notice. IRS guidance suggests as an example a statement on the website reading “Tax Information” linking to a secondary page that includes a statement in capital letters “IMPORTANT HEALTH COVERAGE TAX DOCUMENTS.” That page should explain how to request a copy of the Form 1095-C. The notice must remain on the site through October 15, 2026.
Electronic Filing Required for ACA Reporting
Prior to 2024, employers had the option to file Forms 1094-C and 1095-C (or 1094-B and 1095-B for self-insured non-ALEs) by paper or electronically with the IRS if they were filing fewer than 250 returns. Only employers with 250 or more returns were required to file electronically. However, pursuant to updated IRS electronic filing regulations, paper filing is no longer available.
For more details: IRS Now Requires Electronic Filing for ACA Reporting
Specifically, the regulations now require electronic filing by filers of 10 or more returns in aggregate in a calendar year. This requires filers to consider in aggregate almost all information return types covered by the regulation to determine whether a filer meets the 10-return threshold and is required to e-file their information returns. The new “aggregation of returns” rule means that in calculating whether an employer has at least 10 returns and is required to file electronically, the employer’s Forms W-2, 1099, and multiple other returns (in addition to the Forms 1094-C and 1095-C) are all included together in the 10-return count.
Bottom Line: Employers subject to ACA reporting must electronically file Forms 1094-C and 1095-C (ALEs) or Forms 1094-B and 1095-B (self-insured non-ALEs) with the IRS.
Employers Need to Engage with an ACA Reporting Vendor to File Electronically
ACA reporting forms are filed electronically through the IRS Affordable Care Act Information Returns (AIR) system. The AIR system requires an XML schema coding format for transmission. This process is generally not something that a typical employer can navigate on their own without the support of an ACA reporting vendor. Typical providers of this service include payroll vendors, benefits administration platforms that incorporate ACA reporting services, or stand-alone vendors that specialize in ACA reporting services.
Prior to 2024, some employers filing under 250 returns may have opted to file the returns by paper to avoid the complex AIR system filing. However, that is no longer an option. Employers need to ensure they have engaged with an ACA reporting vendor that can complete the electronic filing on their behalf.
ACA Reporting: Fully Insured vs. Self-Insured Plans
The specific ACA reporting requirements vary depending on whether the employer is an ALE and whether the medical plan it sponsors is fully insured or self-insured. The following overview addresses ACA reporting obligations by employer size and funding arrangement:
ALE Sponsoring a Self-Insured Medical Plan (Including Level Funded)
IRC §6055 and §6056 Reporting
Completed via Forms 1094-C and 1095-C.
Employer must complete Part III of the Form 1095-C (“Covered Individuals”) for enrolled individuals (including COBRA participants).
If the employer sponsors both self-insured and fully insured medical plan options, the employer completes Part III only for individuals enrolled in the self-insured medical plan.
Important Note: Level funded plans are considered self-insured for these purposes.
ALE Sponsoring a Fully Insured Medical Plan
IRC §6056 Reporting Only
Completed via Forms 1094-C and 1095-C.
Employer does
not
complete Part III of the Form 1095-C (“Covered Individuals”).
Insurance carrier completes coverage information on separate Form 1095-B.
Non-ALE Sponsoring a Self-Insured Medical Plan (Including Level Funded)
IRC §6055 Reporting Only
Completed via Forms 1094-B and 1095-B.
Employer does
not
complete Forms 1094-C and 1095-C (b/c not subject to the employer mandate).
Employer information listed in Part III (“Issuer or Other Coverage Provider”) of the 1095-B.
Employer does
not
complete Part II (“Information About Certain Employer-Sponsored Coverage”) of the Form 1095-B.
Important Note:Level funded plans are considered self-insured for these purposes.
Non-ALE Sponsoring a Fully Insured Medical Plan
No ACA Reporting!
For more details: Newfront Compliance Considerations for Self-Insured Plans Guide
ACA Reporting: Controlled Groups
Where an ALE subject to the ACA employer mandate has multiple corporate entities in a controlled group (an Aggregated ALE Group), each subsidiary or related entity in the controlled group must file a separate Form 1094-C. Each entity (EIN) is referred to as an Applicable Large Employer Member (ALEM) for these purposes.
Aggregated ALE Groups have additional ACA reporting obligations as follows:
The Form 1094-C for each ALEM must contain the following:
Part II, Line 21: Each ALEM answers “Yes” to question “Is ALE Member a member of an Aggregated ALE Group?”
Part III, Column (d): For each month in which the controlled group existed, this “Aggregated Group Indicator” box is checked.
Part IV: This “Other ALE Members of Aggregated ALE Group” section is completed listing the names of the other related entities in the controlled group (the other ALEMs) and their EINs.
The Forms 1095-C from each ALEM must contain the following:
The full-time employees of each EIN (i.e., each ALEM) must receive a Form 1095-C with that ALEM’s corporate name and EIN. The employer cannot simply use the parent EIN for all Forms 1095-C in an Aggregated ALE Group. If an employee works for more than one ALEM in the Aggregated ALE Group in any calendar month, the ALEM for whom the employee worked the most hours of service in that calendar month is responsible for the employee’s Form 1095-C ACA reporting for that month.
For more details: ACA Reporting for Controlled Groups
ACA Reporting: Additional Rules for COBRA
Limited COBRA Reporting for Fully Insured Plans: Reduction in Hours
The only additional COBRA-related ACA reporting requirements for employers with a fully insured plan apply for situations where the employee’s qualifying event is a loss of coverage caused by reduction in hours (e.g., full-time to part-time). The appropriate coding in that situation depends on whether the employee elects COBRA and whether the employee has employee-only or family coverage.
Expanded COBRA Reporting for Self-Insured Plans: All COBRA Participants
Self-insured plans (including level funded plans) must report the Part III coverage information for all months of active or COBRA coverage. For individuals whose active coverage terminated in a prior year but were enrolled in COBRA under a self-insured plan for at least one month in the reporting year, the Part II coding reflects that the individual was not an employee for any month of the year (Code “1G” in Line 14 for all 12 months). Additional special coverage reporting rules apply where the spouse or dependent elect COBRA separately.
For more details: ACA Reporting and COBRA
ACA Reporting: Streamlined Reporting Options
ALEs meeting the federal poverty line affordability safe harbor may utilize the Qualifying Offer Method, provided the offer of coverage was also made available to the employee’s spouse and dependents, if any. The federal poverty line affordability safe harbor applies where the lowest possible monthly employee contribution for the major medical plan in 2025 did not exceed $113.20.
Note: The federal poverty line affordability safe harbor for offers in 2026 increases to $129.89/month.
Under the Qualifying Offer Method, the employer lists Code “1A” in Line 14 of the Form 1095-C and leaves blank the contribution amount in Line 15. Line 16 is optional. The employer must check the “Qualifying Offer Method” box in Line 22 (Box A) of the Form 1094-C to take advantage of this approach.
Although generally not recommended, there is also streamlined reporting available through the 98% Offer Method. This (only slightly) streamlined reporting is generally available where the employer offers MEC that provides MV to at least 98% of its full-time employees. Employers utilizing this method do not have to complete the monthly full-time employee count section (Part III, column (b)) of the Form 1094-C.
For more details:
ACA Reporting: Dependent SSN Solicitation Process for Self-Insured Plans
For ALEs sponsoring a self-insured plan (including level funded), Part III includes an SSN entry field for each covered individual. There is no requirement that the employee provide each covered dependents’ SSN, nor is there any requirement that the employer obtain each covered dependents’ SSN from the employee. What is required is that the employer act in a “responsible manner” to obtain each covered dependents’ SSN.
To act in a “responsible manner,” the employer must make three attempts to solicit each covered dependents’ SSN from the employee:
First Solicitation: Employer requests the SSN upon the employee’s election to enroll the dependent. This is referred to as the “account opened” solicitation.
Second Solicitation: Employer requests the SSN again within 75 days of the employee’s election to enroll the dependent. This is referred to as the “first annual solicitation”.
Third Solicitation: Employer requests the SSN a third time by December 31 of the year following the year the employee elected to enroll the dependent. This is referred to as the “second annual solicitation”.
If the employee fails to provide the dependent’s SSN after all three attempts, there is no requirement to continue to solicit the SSN. At this point (as well as during the solicitation process) the employer enters the dependent’s date of birth in Part III, column (c) of the Form 1095-C (instead of the SSN in column (b)).
For more details: ACA Reporting for Employers with a Self-Insured Plan
ACA Reporting Failures: Penalties
The general potential late/incorrect ACA reporting penalties for forms required to be furnished/filed in 2026 are $340 for the late/incorrect Forms 1095 furnished to employees, and $340 for the late/incorrect Forms 1094 and copies of the Forms 1095 filed with the IRS (for a total of $680 per employee).
The 2026 maximum penalty for a calendar year will not exceed $4,098,500 for late/incorrect furnishing or filing. The employer is subject to a penalty of at least $680 per form—with no maximum—if the IRS finds that it intentionally disregarded the filing or furnishing of the correct Forms 1094 and 1095.
The IRS reduces that general penalty if the late/corrected forms are furnished/filed in certain time periods:
30-Day Correction:
If corrected within 30 days of the due date, the per-return penalty is $60 ($683,000 max in 2026).
August 1 Correction:
If corrected by August 1, the per-return penalty is $130 ($2,049,000 max in 2026).
There is also “reasonable cause” relief available that could potentially reduce or eliminate these ACA reporting penalties if the employer can show no willful neglect, that it acted in a responsible manner both before and after the failure occurred, and there were significant mitigating factors or events beyond its control. Those requirements are set forth in Treas. Reg. §301.6724-1. IRS Publication 1586 includes a useful summary of the conditions to qualify for reasonable cause relief.
For more details: ACA Reporting Penalties
ACA Reporting Corrections: Form 1094-C
Form 1094-C:
The IRS directs employers to:
File a standalone, fully completed Form 1094-C with the corrected information included;
Enter an “X” in the “CORRECTED” checkbox at the very top of the Form 1094-C; and
Submit the standalone corrected Form 1094-C Authoritative Transmittal with the correct information included.
Employers do not file Forms 1095-C or any other documents with the corrected Authoritative Transmittal Form 1094-C.
Forms 1095-C Not Filed with the IRS
Correcting Forms 1095-C that were not filed with the IRS requires only re-furnishing the corrected Form 1095-C to the employee. In this case, employers do not enter an “X” in the “CORRECTED” checkbox. Employers instead must write, type, or print “CORRECTED” on the new Form 1095-C furnished to the employee.
Forms 1095-C Filed with the IRS
In this situation, the employer needs to re-furnish the corrected Form 1095-C to the employee and re-file it with the IRS as follows:
Fully complete a corrected Form 1095-C with the error(s) fixed;
Enter an “X” in the “CORRECTED” checkbox on the Form 1095-C;
Submit to the IRS the corrected Forms 1095-C with a nonauthoritative Form 1094-C transmittal;
Do not mark the “CORRECTED” checkbox on the Form 1094-C filed with the corrected Forms 1095-C; and
Furnish a copy of the corrected Form 1095-C to the employee.
For more details: ACA Reporting Corrections
State-Based Individual Mandate Reporting
The TCJA effectively repealed the ACA individual mandate by reducing the penalties to zero as of 2019. As a result, the §6055 coverage information gathered in Part III of the Form 1095-C for a self-insured plan no longer has a clear federal reporting purpose.
Nonetheless, several states have recently added their own state-based individual mandates in response to the effective repeal of the ACA federal individual mandate. Such states include California, Massachusetts, New Jersey, Rhode Island, and Washington D.C. Other than Massachusetts, these states generally rely on the §6055 reporting information by piggybacking off Part III of the Form 1095-C (provided to the state by the employer for self-insured plans) or Form 1095-B (provided to the state by the carrier for fully insured plans) to gather coverage information for residents. Employers sponsoring a self-insured plan should work with their ACA reporting vendor to ensure they complete the filing both with the IRS and the applicable states.
Disclaimer: The intent of this analysis is to provide the recipient with general information regarding the status of, and/or potential concerns related to, the recipient’s current employee benefits issues. This analysis does not necessarily fully address the recipient’s specific issue, and it should not be construed as, nor is it intended to provide, legal advice. Furthermore, this message does not establish an attorney-client relationship. Questions regarding specific issues should be addressed to the person(s) who provide legal advice to the recipient regarding employee benefits issues (e.g., the recipient’s general counsel or an attorney hired by the recipient who specializes in employee benefits law).
Brian Gilmore
Lead Benefits Counsel, VP, Newfront
Brian Gilmore is the Lead Benefits Counsel at Newfront. He assists clients on a wide variety of employee benefits compliance issues. The primary areas of his practice include ERISA, ACA, COBRA, HIPAA, Section 125 Cafeteria Plans, and 401(k) plans. Brian also presents regularly at trade events and in webinars on current hot topics in employee benefits law.
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