When Is ACA Reporting Due: Form 1095-C Deadlines and Tips

ACA reporting for employers relies on Form 1095-C and the related transmittal Form 1094-C. Understanding the due dates helps avoid penalties and ensures accurate, timely communication to employees and the IRS. This guide explains the key deadlines, who must file, and practical steps to prepare, file, and verify information for reliable ACA reporting.

Key Dates For ACA Reporting

ACA reporting hinges on two main deadlines: furnishing forms to employees and filing the same information with the IRS. In general, employers must provide Form 1095-C to each applicable employee by January 31. The IRS filing deadline depends on the method of submission: electronic filing typically has a later deadline than paper filing. For electronic submissions, the IRS accepts filings up to March 31 unless extended by the agency in a given year. If submitting on paper, the deadline is earlier, usually February 28. It is crucial to confirm the current year’s IRS guidance as dates can shift with annual updates.

Who Must File Form 1095-C And Why

Form 1095-C is used to report information about offers of health coverage and enrollment details for members of the employer’s large employer group (LEA). A LEA is generally an employer with 50 or more full-time equivalent employees. Employers in this category must file 1094-C (transmittal) with the IRS and furnish 1095-C forms to full-time employees. Smaller employers may have different reporting requirements or rely on alternative forms for reporting under the Affordable Care Act. Accurate reporting supports tax credit calculations and compliance with ACA mandates.

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What Information Is Needed

Accurate Form 1095-C preparation requires consistent data from payroll, benefits, and human resources. Key data elements include employee identifiers, months worked, offers of coverage, whether the offered coverage was affordable, and coverage details for each month. Employers must verify social security numbers, addresses, and hire status for each employee. Any changes to plan coverage, premiums, or eligibility during the year should be reflected in the forms to avoid mismatches that trigger IRS inquiries.

How To Prepare For ACA Reporting

Preparation begins early in the year. Steps include establishing a centralized data workflow, validating employee records, verifying plan information, and conducting a pre-submission reconciliation. Use payroll and benefits data to determine who is a full-time employee, who received offers of coverage, and whether the coverage was deemed affordable. Create a test run to catch discrepancies before final filing. Maintaining a clear audit trail helps resolve any IRS questions quickly and reduces the risk of penalties.

Filing Methods, Deadlines, And Penalties

Filing options include electronic submissions to the IRS and, in some cases, paper filings. Electronic filing is the preferred method for larger employers and typically has a March 31 deadline if not extended. Paper filings are generally due by February 28. Employers must furnish Form 1095-C to employees by January 31. Penalties apply for missing, late, or incorrect information, with the severity depending on the duration of noncompliance and the number of affected employees. Regular updates to systems and processes help minimize these risks.

Common Pitfalls To Avoid

Common issues include mismatches between employee records and filed data, incorrect social security numbers, and misclassification of full-time versus part-time status. Another frequent problem is failing to timely furnish forms to employees or failing to file by IRS deadlines. Incomplete information about offers of coverage or affordability can trigger questions from the IRS and complicate employee tax filings. Establish internal checks, assign clearly defined responsibilities, and run regular validation checks to prevent these pitfalls.

Practical Tips For 2026 ACA Reporting

  • Confirm the current year’s deadlines with the IRS and adapt your timeline accordingly.
  • Set up a centralized data source for payroll, benefits, and eligibility information.
  • Run a mock submission to catch mismatches before the official filing.
  • Notify employees early about the January 31 deadline for providing 1095-C forms.
  • Maintain documentation of eligibility determinations and offers of coverage.

Resources And Where To Check For Updates

Reliable sources for ACA reporting guidance include the Internal Revenue Service (IRS) and official employer compliance portals. The IRS publishes instructions for Form 1094-C and Form 1095-C, including filing specifications, safe harbor provisions, and penalty guidelines. Employers should monitor IRS News Releases and Instructions for any year-specific changes, extensions, or relief provisions. Additionally, payroll professionals and benefits administrators can leverage reputable compliance guides from professional associations and reputable consulting firms to stay current.

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