Employer resource / Compliance
ACA reporting: identify the coverage year and the filing task.
First determine which reporting rules apply. Then assign data preparation, IRS filing, employee statements, and corrections to named people or vendors.
Quick answer
For 2025 Forms 1095-C, the 2026 dates were March 2 for employee furnishing and March 31 for electronic filing. These dates do not automatically establish deadlines for 2026 coverage reported in 2027.
Determine the reporting population
An applicable large employer generally averaged at least 50 full-time employees plus full-time equivalents in the prior calendar year. For each month, add non-full-time hours of service capped at 120 per person, divide by 120, and add the full-time employee count. Related employers and special rules need review. Self-insured coverage can create reporting obligations for employers below the ALE threshold too.
2025 forms reported in 2026
| Task | Date / condition | Owner to confirm |
|---|---|---|
| Furnish Forms 1095-C | March 2, 2026, unless the alternative furnishing method is properly used. | Employer/reporting vendor. |
| Electronic IRS filing | March 31, 2026 for 2025 forms; extensions and corrections have separate rules. | Authorized filer. |
| Alternative furnishing notice | Compliant notice by March 2, 2026, retained through October 15, 2026. | Website and reporting administrators. |
| Provide requested copies | By the later of January 31, 2026 or 30 days after the request under the alternative procedure. | Named request-response owner. |
Electronic filing and alternative furnishing
The 10-return electronic-filing threshold generally aggregates covered information-return types; do not count only Forms 1095-C. Confirm any waiver or exception with your tax adviser. Alternative furnishing changes how statements are provided to individuals, not the requirement to file with the IRS. Follow the current IRS instructions for notice wording, access, contact information, and timely copies.
Prepare the next cycle
- Identify the correct forms and reporting entities.
- Reconcile employee, hours, offer-of-coverage, and enrollment records with payroll and vendors.
- Assign review, submission, acceptance checks, correction handling, and statement requests.
- Verify final instructions for the relevant coverage year before announcing future deadlines.
WIB can coordinate payroll and vendors, help with benefit statements, and assist with ACA paperwork and notifications. Direct filing and measurement responsibilities must be assigned to the appropriate provider; WIB does not provide tax or legal advice.
Sources checked September 19, 2026. General information; your plan and circumstances matter.
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