The Affordable Care Act (ACA) mandates that insurers, small employers with self-insured health plans, and all Applicable Large Employers report specific information regarding health coverage to the IRS. Additionally, these entities are required to furnish full-time employees and covered individuals with an annual statement (Form 1095) detailing their coverage. Understanding and fulfilling reporting obligations under the ACA is crucial for employers to stay compliant and avoid costly penalties.

Below are a few key things to know about ACA reporting:

• Employers who file 10 or more information returns in aggregate must file their ACA forms electronically. This encompasses nearly all information return types (including forms W-2 and 1099).
   
• Form 1095 for the 2025 reporting year must be furnished to employees by March 2, 2026. Form 1094 along with the 1095s must be filed electronically with the IRS by March 31, 2026.
   
• Employers are no longer required to automatically send form 1095 to individuals. Instead, employers may satisfy the furnishing requirement by posting a reasonably accessible, clear and conspicuous notice on their website informing individuals how to request their 1095. The notice must be posted by March 2, 2026 and include an email address, mailing address, and a phone number that can be utilized to request a copy. The notice should remain at the same location on the employer’s website until October 15, 2026.

What are your reporting obligations?

Review the questions below to determine if you are in compliance:

• Am I considered an Applicable Large Employer (ALE)?
  
  If you had 50 or more full-time or full-time equivalent employees during the previous calendar year you are an ALE. Click here for how to determine ALE status.  It is important to note that companies with a common owner or that are otherwise related under certain rules of section 414 of the Internal Revenue Code are generally combined and treated as a single employer for determining ALE status.
  
  ALEs are covered under the ACA’s Employer Shared Responsibility Provisions (the employer mandate) and are required to offer minimum essential health care coverage that is affordable and provides minimum value to full-time employees and their dependents. Failure to do so may result in substantial financial penalties.
   
• What are my reporting requirements as an ALE?
  
  An ALE must use forms 1094-C and 1095-C to report their compliance with ACA.  Form 1094-C is the authoritative transmittal form, while Form 1095-C provides detailed information about each employee's coverage. These forms must be filed with the IRS and furnished to employees. All ALEs (both fully-insured and self-insured) must complete the 1094-C and 1095-Cs.
  
  The reporting requirements apply to ALEs who offer a group health insurance plan and/or an individual coverage health reimbursement arrangement (ICHRA).
  
  The person responsible for handling ACA reporting should be well-versed in completing these forms accurately, including information on employee enrollment, cost, and affordability coverage. Consistent monitoring and documentation are essential to avoid errors and potential penalties.
   
• If I am NOT considered an Applicable Large Employer (ALE), do I still have reporting obligations?
  
  Small employers (fewer than 50 or more full-time or full-time equivalent employees) who offer self-insured health coverage are responsible for furnishing form 1095-B to enrolled employees and must file these forms along with form 1094-B to the IRS. Form 1095-B shows health insurance coverage, the coverage provider, coverage dates, and individuals covered.
  
  It is important to note that small employers who offer an individual coverage health reimbursement arrangement (ICHRA) are considered self-insured and must follow the 1095B/1094B reporting requirements