- On January 8, 2026
Employers that are required to report health coverage information under the Affordable Care Act (ACA) should begin preparing now for deadlines that apply in early 2026. These requirements pertain to the 2025 calendar year and are outlined in Internal Revenue Code Sections 6055 and 6056.
Key Deadlines for 2026
For 2025 ACA reporting, employers must meet the following obligations:
- IRS Filing Deadline: ACA information returns must be submitted to the IRS electronically no later than March 31, 2026. Employers that file 10 or more information returns during the year are required to file electronically.
- Individual Notice Requirement: By March 2, 2026, employers must either:
- Publish a prominent and easy-to-find notice on their website explaining how individuals can request a copy of Form 1095-B or 1095-C, or
- Provide the applicable form directly to individuals by that date.
If a website notice is used, it must remain available through October 15, 2026. Requested forms must be delivered by the later of January 31, 2026, or 30 days after the request is received.
Employers Subject to ACA Reporting
ACA reporting applies to the following groups:
- Employers that sponsor self-insured health plans (Section 6055)
- Applicable Large Employers (ALEs) with either fully insured or self-insured coverage (Section 6056)
An ALE is generally an employer that averaged 50 or more full-time employees, including full-time equivalents, during the prior calendar year. ALEs that maintain self-funded plans must comply with both reporting sections.
Overview of Sections 6055 and 6056
- Section 6055: Applies to entities that provide minimum essential coverage (MEC), such as insurance carriers and employers with self-insured plans. Reporting is typically completed using 1094-B and 1095-B.
- Section 6056: Applies to ALEs and focuses on whether health coverage was offered to full-time employees. ALEs report this information using 1094-C and 1095-C.
ALEs with self-insured plans may satisfy both reporting requirements by completing Forms 1094-C and 1095-C, rather than filing separate B-series forms.
Filing Extensions
Employers may obtain an automatic 30-day extension to file ACA returns with the IRS by submitting Form 8809 on or before the original due date. Additional extensions may be granted in limited cases involving hardship.
Providing Statements to Individuals
Employers are no longer required to send Forms 1095-B or 1095-C to individuals automatically each year. Instead, they may rely on a website notice that:
- Is clear and easy for individuals to locate
- Includes a mailing address, email address, and phone number for requests
- Is posted by March 2, 2026
- Remains available until October 15, 2026
Alternatively, employers may still choose to furnish statements automatically by March 2, 2026.
Statements may also be delivered electronically if the individual previously gave affirmative consent and has not withdrawn it. Employers must continue to comply with any applicable state-level reporting rules.
Electronic Filing Requirements
For returns filed on or after January 1, 2024, the electronic filing threshold was reduced from 250 returns to 10 returns total, calculated across multiple types of information returns (such as W-2s and 1099s).
Additional reminders include:
- Even if fewer than 10 ACA forms are filed, electronic filing may still be required when combined with other information returns.
- Employers granted a hardship waiver may file on paper, though the IRS strongly encourages electronic submission whenever possible.
- When filing electronically, employers must follow IRS XML schemas and business rules, rather than the paper-form instructions.
ACA Information Returns (AIR) Program
Electronic ACA filings are submitted through the IRS’s AIR Program main page. While much of the available guidance is technical and designed for software developers, employers and service providers may find it helpful for understanding filing standards and transmission procedures.