ACA 1095 Forms: Filing Requirements, Deadlines, Best Practices, and Solutions for Employers

As employers continue to navigate Affordable Care Act (ACA) compliance, Forms 1094 and 1095 remain critical reporting requirements. Failure to file accurately and on time can result in significant IRS penalties, employee confusion, and increased administrative burden. Understanding who must file, key deadlines, and strategies for maintaining accurate data throughout the year can help employers avoid costly compliance issues.

 

What Are Forms 1094 and 1095?

ACA reporting consists of two forms:

Form 1095-C

Provided to employees and filed with the IRS by Applicable Large Employers (ALEs). The form reports:

• Employee health coverage offers
• Coverage affordability
• Months of enrollment
• Employer and employee contribution information

Form 1094-C

The transmittal form submitted to the IRS that summarizes an employer’s ACA reporting data.

Form 1095-B

Used by insurers, self-funded plans that are not ALEs, and other minimum essential coverage providers to report actual coverage enrollment.

 

Which Employers Must File?

Applicable Large Employers (ALEs)

An employer is considered an ALE if it averaged:

• 50 or more full-time employees and full-time equivalent employees during the previous calendar year. Note that the IRS defines a Full Time employee as someone working 30 hours or more per week, on average, over the course of 12 months.
  • If a Part Time employee works 10 hours they will count as 1/3 of a Full Time Equivalent

ALEs must:

• File Forms 1094-C and 1095-C with the IRS.
• Furnish Form 1095-C to employees.

Self-Insured Employers of any size

Self-insured employers of any size must handle 1095 filing. Note that for groups that are level funded and under 50 employees, carriers may handle filing on your behalf.

Small Employers

Employers with fewer than 50 full-time equivalent employees generally are not required to file Forms 1094-C and 1095-C unless they sponsor certain self-funded plans requiring Form 1095-B reporting.

 

ACA Filing Deadlines

Employee Distribution Deadline

Forms 1095-C must generally be provided to employees by:

March 2 following the reporting year

(Subject to IRS adjustments and extensions when announced.)

IRS Electronic Filing Deadline

Employers filing electronically must submit Forms 1094-C and 1095-C by:

March 31 following the reporting year

Electronic filing is mandatory for most employers due to current IRS electronic filing thresholds.

IRS Paper Filing Deadline

Employers eligible to file on paper generally must file by:

February 28 following the reporting year

However, most employers now fall under electronic filing requirements.

 

Penalties for Noncompliance

The IRS may assess penalties for:

• Failure to file forms with the IRS
• Failure to furnish forms to employees
• Inaccurate reporting
• Late filing

Penalties can exceed hundreds of dollars per form and can escalate significantly for large employers with widespread reporting errors.

 

The Importance of Data Integrity Throughout the Year

One of the biggest mistakes employers make is treating ACA reporting as a year-end project.

In reality, successful ACA reporting depends on maintaining accurate data every month. The easiest way to handle this is to use an online enrollment system during the entire year. Further, if this system is connected to payroll, it will help with the data integrity process.

Common Data Issues

Employee Status Errors

• Incorrect full-time versus part-time classifications
• Missed measurement period tracking
• Inaccurate hire dates

Payroll Data Problems

• Incorrect employee contribution amounts
• Missing deductions
• Coding errors affecting affordability calculations

Eligibility Tracking Gaps

• Delayed enrollments
• Incorrect waiting periods
• Failure to capture dependent eligibility

HRIS Integration Challenges

Many employers operate multiple systems:

• Payroll
• HRIS
• Benefits administration
• Timekeeping

When data does not synchronize properly, ACA reporting becomes significantly more difficult.

 

ACA Data Integrity Best Practices

1. Online Benefit Enrollment
2. If using enrollment system outside of payroll (Ex Employee Navigator), connect the system to your payroll system so that data feeds back and forth
3. Have a system in place to measure Part Time (variable hour) employees to confirm if they meet Full Time hours during the year. If they do meet Full Time hours, offer benefits
4. Review contributions to ensure that they are affordable as part of your benefits renewal process
   1. The affordability % for 2026 is 9.96%. Meaning, an employee cannot pay more then 9.96% of their annual income on the cost of employee only coverage for your lowest cost plan
   2. Note, the Federal Poverty Level Safe Harbor for 2026 is $129.89/month

 

ACA Reporting Vendors to Consider

Many employers choose to outsource ACA reporting due to the complexity of coding requirements and electronic filing procedures. The best options for ACA Reporting are typically using your payroll vendor or an HRIS solution such as Employee Navigator.

With these solutions, eligibility, deductions, and employee data feed from the system directly to the forms.

 

Curveballs

Note that several states have their own reporting requirements and deadlines. Trick states can include but are not limited to New Jersey, Massachusets and California

 

About The BRIC Agency

The BRIC Agency helps employers navigate complex employee benefits compliance requirements, including ACA reporting obligations, affordability testing, eligibility tracking, and vendor selection. Our team works with employers to develop year-round compliance strategies that reduce risk and improve reporting accuracy. Contact us to discuss your organization’s ACA compliance needs and reporting processes.