ACA Form Reporting Season Is Here!

ACA reporting season has arrived, and employers that sponsor group health plans should be prepared to meet their reporting obligations under IRC Sections 6055 and 6056 as applicable. The reporting involves timely filing forms with the IRS and furnishing copies to individuals.

Background

There are two separate ACA reporting obligations under IRC Sections 6055 and 6056.

Employers that sponsored a self-insured plan, including a level-funded plan, during 2025 must comply with Section 6055 reporting in 2026. Self-insured employers with fewer than 50 full-time employees must complete Form 1095-B with such information. Self-insured applicable large employers (ALEs) must complete Section III of Form 1095-C detailing which months the employee (and any applicable spouse and dependents) had coverage under the employer's plan. ALEs are employers, as defined on a controlled group basis, with 50 or more full-time employees, including full-time equivalent employees, in the prior year.

Additionally, ALEs must comply with IRC Section 6056 reporting by completing and filing Form 1095-C for full-time employees. The form should include details regarding whether the employee was offered minimum value, affordable coverage during 2025.

The forms must be filed with the IRS by March 31, 2026, and generally, furnished to employees and covered participants by March 2, 2026.

Requirements for Furnishing Forms

As noted above, the forms must not only be filed with the IRS but also furnished to individuals. The forms can be delivered to individuals by mail, hand delivery, or electronic delivery (the latter if proper consent is provided in accordance with IRS instructions) by March 2, 2026. However, as explained below, an alternative method is available for furnishing the forms.

Under the alternative method, the employer must post a clear and conspicuous notice on a website (accessible to individuals who may request a form) of the document's availability and the necessary contact information (email address, physical address, and phone number) to request it. Any such request must be fulfilled within 30 days or by January 31, if later. The notice must remain on the website through October 15 of the year following the calendar year.

Additionally, note that state individual mandates in CA, DC, MA, NJ, and RI generally require employers to distribute Form 1095-B or Form 1095-C to employees residing in those states by separate annual deadlines; thus, employers cannot furnish these forms only upon request using the alternative method.

Electronic IRS Filing Requirement

Finally, as a reminder, employers that file 10 or more returns of any type (i.e., counting Form 1094-B/1095-B, 1094-C/1095-C, W-2, and 1099 together) to the IRS in a calendar year must do so electronically absent a hardship waiver. For those employers still able to file by paper, the filing deadline is February 28, 2026.

For further information on the reporting requirements, please refer to IRS Form 1095-B, IRS Form 1095-C, IRS Form 1095-B Instructions, IRS Form 1095-C Instructions. PPI clients can access the Client Help Center for copies of the PPI publications ACA: Employer Mandate Reporting Requirements and ACA: FAQs for Employer Reporting Under Sections 6055 and 6056.