What is the ACA reporting deadline for 2026?

Editorial team Published on

The 2027 ACA Open Enrollment Period begins on November 1, 2026 for most states, with upcoming deadlines varying by coverage year and reporting requirements.

📅 2027 Coverage Open Enrollment (Upcoming)

  • November 1, 2026: Open enrollment starts
  • December 15, 2026: Deadline for Jan 1 coverage
  • January 15, 2027: Open enrollment ends in most states

📊 Employer ACA Reporting Deadlines (For 2025/2026 Tax Year)

  • March 2, 2026: Form 1095-C furnished to employees
  • March 31, 2026: Electronic filing of Forms 1094-C and 1095-C with the IRS

💡 State-Based Marketplace Variations (2027 Coverage)

State-run marketplaces often extend deadlines past January 15 or start earlier:

  • Idaho: Starts October 15, ends December 15
  • Connecticut & Massachusetts: Start October 23
  • California, New Jersey, New York: Extended enrollment through January 31, 2027

Is ACA reporting still required for 2026?

Yes, Affordable Care Act (ACA) reporting is still required in 2026 for the 2025 tax year, and the mandate continues for applicable entities.

Who Must File

  • Applicable Large Employers (ALEs): Organizations with 50 or more full-time or full-time-equivalent employees during the prior calendar year must file.
  • Self-Insured Employers: Employers of any size that sponsor self-insured health plans must file coverage reports.

Key Requirements & Changes

  • Electronic Filing: E-filing via the Affordable Care Act Information Returns (AIR) system is mandatory if you file 10 or more return forms in aggregate.
  • Furnishing Forms: Employers must provide Form 1095-C or 1095-B to individuals, or utilize the alternative online notice availability option where permitted (though direct furnishing may still be required by certain states with individual mandates).
  • State-Level Reporting: States like California, New Jersey, Rhode Island, Massachusetts, and Washington D.C. maintain separate state-level health coverage mandates and distinct filing requirements.

What are the deadlines for ACA reporting?

For the 2025 tax year reporting (filed in 2026), key federal Affordable Care Act (ACA) deadlines and requirements can be reviewed on the IRS ACA Information Center for ALEs.

Federal ACA Deadlines

  • Employee/Recipient Furnishing (Forms 1095-B / 1095-C): March 2, 2026 (or via an eligible web notice posted from March 2 through October 15, 2026, where forms are provided upon request).
  • IRS Paper Filing: March 2, 2026 (applies only to employers filing 10 or fewer total returns).
  • IRS Electronic Filing: March 31, 2026 (mandatory for employers filing 10 or more aggregate information returns).

State-Level ACA Reporting Deadlines

If you have employees residing in states with individual health mandates, separate state filing and furnishing deadlines apply:

  • California: Furnish to employees by January 31, 2026; state filing by March 31, 2026.
  • New Jersey & Rhode Island: Furnish to employees by March 2, 2026; state filing by March 31, 2026.
  • Massachusetts: Furnish and file Form MA 1099-HC by February 2, 2026.
  • Washington, D.C.: State filing by April 30, 2026.

Is ACA reporting mandatory?

Affordable Care Act (ACA) reporting is mandatory for applicable large employers and entities that provide self-insured health coverage.

Who Must Report

  • Applicable Large Employers (ALEs): Businesses with an average of 50 or more full-time equivalent employees in the prior year must file. They use IRS Form 1094-C and Form 1095-C.
  • Self-Insured Employers: Small employers that sponsor self-insured health plans must report coverage details under Section 6055 using IRS Form 1094-B and Form 1095-B.
  • Health Insurance Providers: Insurers and other providers of minimum essential coverage must also file annual returns.

Key Requirements

  • Electronic Filing: Mandatory for any organization filing a total of 10 or more information returns with the IRS.
  • Penalties: Failing to file accurate and timely returns can result in substantial IRS penalties per form.

What's going to happen to ACA in 2026?

In 2026, the Affordable Care Act (ACA) marketplace is facing higher premiums, record-high deductibles, and lower enrollment following the expiration of pandemic-era enhanced premium tax credits at the end of 2025.

Expiration of Enhanced Subsidies and Costs

  • Higher Premiums and Deductibles: According to KFF, average monthly net premium payments rose by 58%, and average marketplace deductibles jumped by 37% to a record high of $3,786 as many enrollees shifted to cheaper bronze-tier plans.
  • Enrollment Decline: National effectuated enrollment fell by roughly 12% to 19.2 million people early in the year, with a disproportionate drop among individuals with incomes just above the 400% federal poverty level subsidy cliff.
  • General Healthcare Inflation: Elevated healthcare costs are continuing to pressure the market, with projections pointing toward continued premium growth heading into future years as detailed by CNBC.

Policy and Administrative Changes

  • Budget and Legislative Shifts: Changes under the American Medical Association advocacy tracking have reduced federal funding for certain health programs and altered rules for marketplace participants. Meanwhile, lawmakers have introduced proposals in Congress to reinstate enhanced subsidies, as reported by Becker's Payer.
  • Fraud and Integrity Enforcement: The Trump administration enacted stricter marketplace integrity rules, moving to disenroll hundreds of thousands of enrollees flagged for improper or missing documentation while issuing targeted refund checks to other participants.

April 30, 2026 ACA Reporting Deadline: What NY Employers Must Know

9 related questions found

What is the ACA affordability threshold for 2026?

The Affordable Care Act (ACA) affordability threshold for plan years beginning in 2026 is 9.96% of an employee's household income (or applicable safe harbor wages). This is an increase from the 2025 rate of 9.02%.

Overview of 2026 Affordability

  • Percentage Limit: The employee's required monthly contribution for the lowest-cost, self-only coverage option providing minimum value cannot exceed 9.96% of their income.
  • Comparison: This marks an increase from 2025 (9.02%) and gives employers more flexibility regarding employee premium contributions.

Employer Safe Harbors for 2026

To avoid calculating individual household incomes, employers can use one of three IRS IRS Announces 2026 ACA Affordability Indexed Amount safe harbors:

  • Form W-2 Safe Harbor: Monthly self-only contribution is ≤ 9.96% of Box 1 W-2 wages.
  • Rate of Pay Safe Harbor: Monthly self-only contribution is ≤ 9.96% of computed monthly wages (hourly rate × 130 hours, or monthly salary).
  • Federal Poverty Line (FPL) Safe Harbor: Monthly self-only contribution is ≤ 9.96% of the applicable Federal Poverty Line amount. For the mainland U.S., this generally caps the lowest-cost monthly employee contribution around $129.89 (depending on exact FPL updates).

What is an ale for ACA reporting?

An ALE in ACA reporting stands for an Applicable Large Employer, which is a business or organization that employed an average of at least 50 full-time or full-time equivalent (FTE) employees during the prior calendar year.

What ALE Status Means

  • Employer Mandate: ALEs must offer affordable health coverage that meets minimum essential coverage (MEC) standards to at least 95% of their full-time employees and their dependents, or risk paying penalties.
  • Reporting Requirements: ALEs must file annual information returns with the Internal Revenue Service (IRS) and provide statements to employees detailing the health insurance coverage offered. This is done using Form 1094-C (transmittal) and Form 1095-C (employee statement).

How to Determine ALE Status

  • Full-Time Definition: Under the Affordable Care Act (ACA), a full-time employee works an average of at least 30 hours per week (or 130 hours in a calendar month).
  • FTE Calculation: Part-time employee hours are combined and divided by 120 to calculate full-time equivalent employees for each month.
  • Prior Year Average: Total full-time and FTE employees for each month of the previous calendar year are added together and divided by 12. If the final average is 50 or more, the company is an ALE for the current calendar year.
  • Official Guidance: You can review detailed criteria and calculation steps directly on the IRS ALE Info Center.

How do I file ACA reporting?

To file Affordable Care Act (ACA) reporting, you can submit your forms electronically through the IRS AIR System if you are filing 10 or more returns.

Determine Your Requirements

  • Applicable Large Employers (ALEs): Businesses with 50 or more full-time or full-time equivalent employees must file.
  • Self-Insured Employers: Smaller employers with self-insured health plans must also file.
  • Forms Needed: Use Form 1095-C and transmittal Form 1094-C for ALEs, or Form 1095-B and transmittal Form 1094-B for insurance providers and small self-insured groups.

Steps to File

  1. Apply for a TCC: Apply for an ACA Transmitter Control Code (TCC) via the IRS ACA Services Portal if you are a new electronic filer.
  2. Gather Data: Collect employee details, Employer Identification Number (EIN), monthly employee counts, and coverage offer codes (Series 1 and 2 codes).
  3. Furnish Employee Copies: Provide Form 1095-B or 1095-C copies to applicable employees early in the year (typically by early-to-mid March).
  4. Submit to the IRS: E-file your XML-formatted data through the AIR system by the March 31 electronic deadline, or mail paper forms if you qualify for the under-10 exemption.

When did ACA reporting go into effect?

Affordable Care Act (ACA) employer reporting requirements went into effect for the 2015 tax year (with initial filings submitted to the IRS in early 2016), following the passage of the ACA into law on March 23, 2010.

Key Milestones

  • March 23, 2010: The Affordable Care Act was signed into law.
  • 2014: Core provisions of the ACA (like the employer and individual mandates) took effect.
  • 2015 Tax Year: Mandatory reporting under Internal Revenue Code sections 6055 and 6056 officially began, requiring Applicable Large Employers (ALEs) and coverage providers to file Forms 1094 and 1095.
  • Recent Updates: Reporting rules were updated under the Paperwork Burden Reduction Act starting with the 2024 reporting year (filed in early 2025) to ease certain distribution burdens.

Who is required to file a 1094 and 1095 form?

Employers with 50 or more full-time or full-time equivalent employees (Applicable Large Employers) and all self-insured employers regardless of size must file IRS Forms 1094 and 1095.

Who Must File Forms 1094-C and 1095-C (For ALEs)

  • Applicable Large Employers (ALEs): Businesses that averaged 50 or more full-time employees (including full-time equivalents) during the previous calendar year.
  • Form 1095-C: Must be furnished to every full-time employee and filed with the IRS Instructions for Forms 1094-C and 1095-C to report health coverage offers.
  • Form 1094-C: Acts as the transmittal cover sheet summarizing the 1095-C forms submitted to the IRS.

Who Must File Forms 1094-B and 1095-B (For Self-Insured Coverage)

  • Small Self-Insured Employers: Businesses with fewer than 50 employees that sponsor a self-insured or level-funded health plan must file "B" series forms.
  • Insurance Providers / Insurers: Health insurance companies and other providers of minimum essential coverage file these forms for individuals enrolled in fully insured plans.