Upcoming ACA Form 1094/5 Reporting Deadlines

Applicable large employers (ALEs) with 50 or more full-time employees (FTEs), including full-time equivalent employees, in the prior year who sponsored group health plans (whether insured or self-insured) must comply with IRC Section 6056 reporting in early 2024. Specifically, ALEs must complete and distribute Form 1095-C to full-time employees by March 1, 2024. The form should include details regarding whether the employee was offered minimum value, affordable coverage during 2023. The forms may be mailed, electronically delivered or delivered by hand (although proof of delivery in some manner is recommended).

Employers who sponsored a self-insured plan during 2023 must comply with Section 6055 reporting in 2024. Self-insured 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. If the self-insured employer has fewer than 50 FTEs, it must complete and distribute a Form 1095-B with such information. Again, the forms must be delivered to employees by March 1, 2024.

If the self-insured employer has fewer than 50 FTEs, an alternative is available to distributing Form 1095-B to individuals. These small employers are permitted to post a clear and conspicuous notice on their website of the document's availability and the necessary contact information to request it. Any such request must be fulfilled within 30 days. This alternative is not available for Form 1095-C.

Employers must also file the forms with the IRS by February 28, 2024, if filing by paper, and April 1, 2024, if filing electronically. The filing must include the transmittal Form 1094-C (if filing Forms 1095-C) or Form 1094-B (if filing Forms 1095-B). Importantly, beginning this year, employers that file 10 or more returns of any type (i.e., counting Forms 1094/1095, W-2, and 1099 together) to the IRS in a calendar year must do so electronically absent a hardship waiver. Please see our article for more information on this change.

Additionally, employers with employees located in states with an individual mandate may also have to comply with state reporting requirements and should be aware of the applicable deadlines.

For more information on ACA and/or state reporting requirements, please download a copy of our ACA: Employer Mandate Reporting Requirements and State Individual Mandate Reporting Requirements publications below.

2023 Form 1094-C »
2023 Form 1095-C »
2023 Form 1094-B »
2023 Form 1095-B »
2023 Instructions for Forms 1094-C and 1095-C »
2023 Instructions for Forms 1094-B and 1095-B »