2026 ACA Reporting Deadlines and Compliance Requirements for the 2025 Calendar Year

As employers prepare for the next Affordable Care Act (ACA) reporting cycle, understanding the 2026 deadlines and new compliance options is critical. The IRS has finalized the reporting forms and instructions for the 2025 calendar year, along with updates that simplify the process for Applicable Large Employers (ALEs).

Here’s what employers need to know.

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Key ACA Reporting Deadlines for 2026

Applicable Large Employers (ALEs) must meet the following ACA reporting deadlines for the 2025 calendar year:

• Employee Forms (1095-C):
  Must be furnished to employees no later than March 2, 2026.
  Alternatively, ALEs may now post an online notice of availability instead of distributing the forms to all employees individually.
• IRS Filing (Forms 1094-C and 1095-C):
  Must be electronically filed with the IRS by March 31, 2026.

Non-ALEs that sponsor self-insured or level-funded plans face the same deadlines when submitting Forms 1094-B and 1095-B.

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ACA Reporting Overview

Under the ACA, employers are required to report information about health coverage offered to employees:

• ALEs (employers with 50 or more full-time or full-time equivalent employees) must report whether they offered minimum essential coverage (MEC) that was affordable and provided minimum value.
• Employers with self-insured plans—including level-funded arrangements—must also report months of coverage for all enrolled individuals.

Reporting is completed through IRS Forms 1094-C and 1095-C (for ALEs) or 1094-B and 1095-B (for non-ALE self-insured plans).

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New Option: “Alternative Manner of Furnishing” Employee Forms

Thanks to the Paperwork Burden Reduction Act (PBRA), ALEs now have a new way to fulfill their reporting obligations without furnishing a Form 1095-C to every full-time employee.

Instead, employers can:

1. Post a Notice of Availability:
   Make a clear, conspicuous notice available on the company’s benefits website by March 2, 2026, informing employees they may request a copy of their Form 1095-C.
2. Provide Upon Request:
   Furnish a copy by the later of January 31 or 30 days after the employee’s request.

The online notice must:

• Use plain language and legible formatting (e.g., a large font or graphics that draw attention).
• Remain accessible through October 15, 2026.
• Include clear instructions on how to request the form.

Example:
A “Tax Information” link on a benefits website leading to a page labeled “IMPORTANT HEALTH COVERAGE TAX DOCUMENTS” with instructions for obtaining the form.

This streamlined furnishing method mirrors an existing option for insurance carriers and non-ALEs reporting via Form 1095-B.

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Electronic Filing Now Required for All Employers

Starting with the 2025 reporting year, the IRS now requires electronic filing for virtually all ACA reports.
Previously, employers filing fewer than 250 forms could submit on paper—but that’s no longer an option.

Under the new aggregation rule, employers that file 10 or more total information returns (including Forms W-2, 1099, and ACA forms) must file electronically through the IRS Affordable Care Act Information Returns (AIR) system.

Because the AIR system requires a specific XML schema format, most employers will need to work with an ACA reporting vendor—such as a payroll provider, benefits administration platform, or specialized ACA reporting service.

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Penalties for Late or Incorrect ACA Reporting

Failure to comply with ACA reporting requirements can be costly.
For forms due in 2026, the IRS penalties are as follows:

Violation	Penalty per Form	Maximum Annual Penalty
Late or Incorrect Filing or Furnishing	$340	$4,098,500
Intentional Disregard	$680 per form (no max)	—

Reduced Penalties for Timely Corrections

• Within 30 days of due date: $60 per form (max $683,000)
• By August 1, 2026: $130 per form (max $2,049,000)

Employers may also qualify for “reasonable cause” relief if they can demonstrate responsible efforts to comply and mitigating circumstances beyond their control (see Treas. Reg. §301.6724-1 and IRS Publication 1586).

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Action Steps for Employers

To prepare for 2026 ACA reporting:

1. Confirm ALE status and determine which forms (1094/1095-B or -C) apply.
2. Decide whether to furnish forms directly or use the online notice of availability option.
3. Engage an ACA reporting vendor capable of e-filing through the IRS AIR system.
4. Review 2025 IRS Forms 1094-C, 1095-C, and instructions to ensure accurate completion.
5. Establish internal deadlines to avoid costly penalties.

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Bottom Line

For 2026, ACA reporting brings both greater convenience and stricter electronic filing rules.
Employers should take advantage of the new online furnishing option while ensuring they’re ready to meet the March deadlines and avoid compliance penalties.