2026 ACA Reporting Guide: Key Deadlines and Compliance Requirements

Employers must prepare for Affordable Care Act (ACA) reporting covering the 2025 calendar year. Staying ahead of these deadlines is critical for Applicable Large Employers (ALEs) and providers of self-insured health plans.

Who is Required to Report?

Reporting obligations under Internal Revenue Code Sections 6055 and 6056 fall into two main categories:

• Self-Insured Health Plan Providers (Section 6055): Any entity providing minimum essential coverage (MEC), including non-ALEs with self-insured plans.
• Applicable Large Employers (ALEs) (Section 6056): Organizations with 50 or more full-time employees (including equivalents).

Note for Self-Insured ALEs: If you are an ALE with a self-funded plan, you must comply with both requirements. However, you can simplify the process by using a single combined filing (Forms 1094-C and 1095-C).

Important Filing Deadlines for 2026

How to Furnish Statements to Individuals

Employers have two options for providing Forms 1095-B or 1095-C to covered individuals:

1. Direct Delivery: Automatically mail or electronically deliver the forms by March 2, 2026.
2. Website Notice Alternative: Instead of mailing every form, you may post a “clear, conspicuous, and easily accessible” notice on your website by March 2, 2026.
3. The notice must state that individuals can request a copy of their form.
4. It must include an email address, physical address, and phone number for requests.
5. Requests must be fulfilled within 30 days.

Mandatory Electronic Filing

The IRS now requires electronic filing for almost all employers.

• The 10-Return Threshold: If you file 10 or more information returns in total (including W-2s, 1099s, and ACA forms combined), you must file your ACA returns electronically.
• The System: Electronic filings must be submitted through the ACA Information Returns (AIR) Program using specific XML formatting.

Extensions and Hardships

• Automatic Extension: You can secure an additional 30 days to file with the IRS by submitting Form 8809 by the original March 31 deadline.
• Hardship Waivers: While the IRS encourages electronic filing for everyone, waivers may be available for those facing significant technological or financial hardships.

Get clear, practical steps now so you’re not scrambling on March 31.