Alhassane Diallo | Feb 02 2026 14:01
The Affordable Care Act (ACA) has transformed the landscape of health coverage reporting for employers and individuals alike. As we approach the 2026 filing season, understanding the requirements for Forms 1095-C and 1095-B—and how to stay compliant—remains essential for businesses and employees. Here’s what you need to know to navigate ACA reporting with confidence.
Who Must File? The Basics of ACA Reporting
Applicable Large Employers (ALEs):
If your business averaged 50 or more full-time employees (including full-time equivalents) in the previous year, you’re considered an ALE. This means you must file Form 1095-C for each full-time employee, regardless of whether they enrolled in your health plan. If you offer a self-insured plan, you’ll also report coverage for all enrolled individuals (including part-time employees and dependents) on Part III of Form 1095-C. The IRS requires you to transmit these forms using Form 1094-C.
Small Employers with Self-Insured Plans:
Employers with fewer than 50 full-time employees who sponsor self-insured health plans must file Forms 1095-B and 1094-B, reporting coverage for all enrolled individuals.
Insurers and Other Coverage Providers:
Health insurance issuers and other entities providing minimum essential coverage (MEC) also file Forms 1095-B and 1094-B.
What Information Is Reported?
- Form 1095-C: Includes employer and employee details, the type and months of coverage offered, and (if self-insured) information about all covered individuals.
- Form 1095-B: Reports coverage details for each individual enrolled in a self-insured plan or through an insurer.
2026 Deadlines: Mark Your Calendar
For the 2025 tax year (filed in 2026), the ACA reporting deadlines are:
- Furnishing to Employees/Individuals:
March 2, 2026. However, for 2024 and later years, you only need to provide Forms 1095-C or 1095-B to individuals upon request, as long as you’ve given a clear and conspicuous notice about their availability. If requested, the form must be provided by the later of January 31 or 30 days after the request.
- Filing with the IRS:
- Paper filers: March 2, 2026
- Electronic filers: March 31, 2026
- (Employers filing 10 or more returns must file electronically unless a waiver is obtained).
- Need More Time? You can request an automatic 30-day extension to file with the IRS by submitting Form 8809.
Best Practices for ACA Compliance
- Prepare and Review Carefully:
Double-check all information, especially the codes on Form 1095-C, to avoid common errors that can trigger IRS penalties.
- File and Furnish on Time:
Meet all deadlines and use electronic filing if you have 10 or more returns. Request extensions if needed.
- Correct Errors Promptly:
If you discover mistakes after filing, submit corrected forms as soon as possible. If you receive an IRS notice (like Letter 226-J), follow the instructions for corrections.
- Keep Good Record:
Retain copies of all filed forms or be able to reconstruct the data for at least three years.
- Protect Personal Information:
Truncate Social Security Numbers or Taxpayer Identification Numbers on recipient copies to help prevent identity theft.
- Provide Clear Notice: For 2024 and beyond, make sure employees know how to request their forms by providing a clear, accessible notice.
- Respond to IRS Notices: If you receive a notice from the IRS, respond promptly and provide any required documentation.
Tips for Individuals
- Review all Forms 1095 for accuracy and request corrections if needed.
- Keep copies of your forms for your records and use them to complete your tax return, especially if you’re claiming the Premium Tax Credit.
Stay Ahead of ACA Reporting
ACA reporting doesn’t have to be overwhelming. By understanding your obligations, meeting deadlines, and following best practices, you can ensure compliance and avoid costly penalties. Stay informed, stay organized, and make ACA reporting a smooth part of your annual process!