ACA Reporting Deadlines and Requirements: A Complete Guide for Brokers and Employers for Tax Year 2025
As the 2025 calendar year draws to a close, brokers and employer clients alike should be preparing now for the ACA reporting season for tax year 2025. Accurate and timely form distribution and e-filing with the IRS are essential, and evolving rules bring both new flexibility and new risks.
Fortunately, solutions like the Mitratech Mineral ACA Reporting Hub help take the guesswork out of ACA compliance. From data validation to e-filing and year-round compliance tracking, brokers and employers can rely on technology and expertise to stay ahead.
In this guide, you will find:
- Firm deadlines for ACA reporting in 2026 (for tax year 2025)
- What is new or changed in ACA reporting rules
- Common ACA reporting mistakes and how to avoid them
- State-level ACA reporting requirements
- A year-round ACA compliance strategy
- A pre-January 1, 2026 checklist for brokers and employers
- Advice for brokers on how to guide clients through ACA compliance
Key ACA Reporting Deadlines for Tax Year 2025
| Date | Action | Notes |
| February 28, 2026 | Paper filing of IRS Forms 1094 / 1095 (if eligible) | Paper filing is allowed only for employers submitting fewer than 10 aggregated returns (e.g., 1095, W-2). |
| March 2, 2026 | Furnish IRS Form 1095-C (or 1095-B as applicable) to employees | The permanent 30-day extension from January 31 is in effect. |
| March 2, 2026 | Post “Notice of Availability” (for alternative furnishing approach) | Required if the employer is using the alternate furnishing method where individuals must request their statements. It must remain posted until October 15, 2026 |
| March 31, 2026 | Electronic filing of Forms 1094 / 1095 with IRS | All filers submitting 10 or more aggregated returns are required to file electronically through the IRS AIR system. |
| January 31, 2027 (or 30 days after a request, whichever is later) | Furnish requested 1095 statements under the alternative furnishing method | Applies when individuals request the 1095 forms. |
Meeting these deadlines is non-negotiable. Missing them can trigger per-form penalties and unnecessary compliance exposure.
Pro Tip: The Mitratech Mineral ACA Reporting Hub automatically tracks key deadlines and sends alerts before submission dates to help employers and brokers avoid last-minute filing stress.
New to ACA Reporting?
If you are new to ACA reporting or need a quick refresher, watch our on-demand webinar ACA Compliance 101: Understanding the Law, Determining ALE Status, and Choosing the Right Forms.
You’ll learn the essentials of ACA compliance, how to identify Applicable Large Employers (ALEs), and which forms you need to file.
🎥 Watch Now: ACA Compliance 101 Webinar
Get Ready for ACA Season: What’s New and What to Watch in 2025
Staying up to date with ACA requirements helps brokers and clients maintain compliance and confidence.
1. Alternative Furnishing (Only Upon Request)
Employers and insurers are no longer required to automatically furnish 1095-C or 1095-B forms. Instead, statements must be provided only if individuals request them, provided the employer posts a clear, specific, and accessible notice on their website explaining the form is available upon request and how to obtain it
Pro Tip: Mitratech Mineral’s built-in policy guidance helps employers create a compliant “Notice of Availability” template and store proof of posting, eliminating manual tracking and version control issues.
2. Electronic Filing Now Mandatory for Most Employers
Any organization filing 10 or more information returns in total (including W-2s, 1099s, and ACA forms) must e-file via the IRS AIR system.
Pro Tip: With the Mitratech Mineral ACA Reporting Hub, employers can upload, validate, and file forms electronically in minutes, ensuring compliance with the IRS e-file threshold.
3. Use of Date of Birth When SSN or TIN Is Unavailable
Employers may now use a covered individual’s date of birth if a Social Security Number or TIN cannot be obtained. This reduces the need to document “reasonable cause” for missing numbers.
Pro Tip: The Mitratech Mineral platform flags missing or invalid SSNs early and provides real-time validation so data can be corrected before filing season begins.
4. Extended Time to Respond to IRS ACA Penalty Letters
Employers now have 90 days to respond to an IRS Letter 226-J instead of 30. This rule applies to letters issued on or after January 1, 2025.
Pro Tip: Mitratech Mineral users can track compliance records and furnish documentation quickly, which is critical for defending against ACA penalty notices.
5. Six-Year Statute of Limitations for ACA Penalties
For employer shared responsibility failures after December 31, 2024, the IRS only has six years to assess penalties under Code § 4980H.
Pro Tip: The Mitratech Mineral ACA Reporting Hub keeps a secure digital archive of all filings and correspondence so employers can maintain the full six-year audit trail required by the IRS.
Managing Part-Time, Seasonal, or Temporary Workers?
If your workforce includes part-time, seasonal, or temporary employees, ACA reporting can get complicated fast. Watch our on-demand webinar One Size Doesn’t Fit All: ACA Compliance for Employers with Part-Time, Seasonal, or Temporary Workers.
Learn how to accurately track variable-hour employees, determine eligibility, and stay compliant across complex workforce models.
🎥 Watch Now: One Size Doesn’t Fit All – ACA Compliance for Employers with Part-Time, Seasonal, or Temporary Workers
Common ACA Reporting Mistakes and How to Avoid Them
Even seasoned HR and benefits teams can make costly errors when preparing ACA forms. Here are some of the most common mistakes and how to avoid them.
| Common Mistake | Why It Happens | How Mitratech Mineral Helps |
| Missing or incorrect employee data | Manual entry or outdated HRIS records | Mitratech Mineral’s data validation automatically flags missing or inconsistent information before submission |
| Late filing | Poor deadline tracking or last-minute prep | Built-in calendar reminders and alerts keep every client on schedule |
| Incorrect ALE status calculation | Miscounting full-time equivalent or variable-hour employees | The Mitratech Mineral ACA Reporting Hub automatically calculates ALE status based on hours of service |
| State filing gaps | Overlooking state-specific reporting rules | Mitratech Mineral includes tools and updates for CA, NJ, MA, RI, and DC |
| Unfurnished or mis-mailed 1095 forms | Failing to meet form distribution requirements | The platform includes mail fulfillment and tracking for audit readiness |
Pro Tip: Regularly review your ACA data throughout the year, not just during Q1. With Mitratech Mineral’s continuous compliance tools, employers can monitor ACA eligibility and coverage accuracy month by month.
Have ACA Reporting Questions?
Get answers straight from the experts in our on-demand session Ask the Experts: The Mineral Experts™ Tackle Your Top ACA Reporting Challenges.
Hear how Mitratech Mineral’s compliance specialists address real-world reporting issues, from tricky coverage codes to correcting filing errors and managing complex multi-entity submissions.
🎥 Watch Now: Ask the Experts – The Mineral Experts™ Tackle Your Top ACA Reporting Challenges
State-Level ACA Reporting Requirements
In addition to federal ACA reporting, several states require their own submissions for individual mandates.
| State | Requirement | Filing Due Date | Mitratech Mineral Support |
| California | Form submission to the CA Franchise Tax Board | March 31 | Integrated in the Mitratech Mineral ACA Reporting Hub |
| New Jersey | Electronic form submission to NJ Division of Taxation | March 31 | Integrated in the Mitratech Mineral ACA Reporting Hub |
| Massachusetts | Electronic submission of form 1099-HC to the MA DOR | January 31 | Mitratech Mineral provides direction and Expert support for employers |
| Rhode Island | Electronic form submission to the RI Division of Taxation | March 31 | Integrated in the Mitratech Mineral ACA Reporting Hub |
| District of Columbia | Electronic form submission to DC OTR | April 30 | Integrated in the Mitratech Mineral ACA Reporting Hub |
Pro Tip: State reporting requirements can change annually. Mitratech Mineral automatically updates its filing templates and workflows to align with the latest state mandates.
Navigating Multi-State or Multi-Employer Reporting?
For a deeper dive into complex reporting scenarios, watch our on-demand webinar Beyond the Basics: Mastering ACA Compliance for Multi-State or Multi-Employer Groups.
Learn how to manage overlapping federal and state requirements, streamline reporting across multiple entities, and avoid common filing mistakes.
🎥 Watch Now: Beyond the Basics: Mastering ACA Compliance for Multi-State or Multi-Employer Groups
Build a Year-Round ACA Compliance Strategy
ACA compliance does not end after filing season. Proactive brokers and employers use the rest of the year to strengthen data integrity and readiness.
- Quarterly data reviews: Spot discrepancies in eligibility or coverage early.
- Midyear training: Schedule HR refreshers on ACA tracking and employee classification.
- Technology alignment: Ensure HRIS, payroll, and benefits systems sync properly with ACA tools.
- Vendor collaboration: Work with vendors such as Mitratech Mineral to align ACA reporting with broader HR compliance goals.
Pro Tip: The Mitratech Mineral ACA Reporting Hub integrates with leading HR and payroll systems, making continuous data validation easy and automatic all year long.
Avoid the Crunch: Build Your ACA Game Plan Now
The best way to simplify ACA reporting is to start early. Read our blog Avoid the Crunch: Build Your ACA Game Plan Now to learn how to prepare your data, plan your filing strategy, and set key milestones before year-end.
You’ll get practical tips for avoiding last-minute errors, improving data accuracy, and using the Mitratech Mineral ACA Reporting Hub to stay ahead of every deadline.
📘 Read Now: Avoid the Crunch – Build Your ACA Game Plan Now
Pre-January 1, 2026 Checklist for Brokers and Employers
Brokers and employers should use this checklist to prepare early and avoid filing errors.
| Task | Description | Broker Role |
| Review past filings and error reports | Identify rejected returns, missing SSNs, or recurring mistakes | Help clients prepare for possible rejections and guide data clean-up |
| Verify and clean employee data | Check all names, addresses, SSNs, dates of birth, and coverage months | Encourage clients to use Mitratech Mineral’s data validation tools and resources |
| Confirm vendor or software readiness | Ensure systems are ready for e-filing and schema updates | Recommend the Mitratech Mineral ACA Reporting Hub for integrated filing |
| Decide on furnishing method | Choose whether to adopt alternative furnishing or continue automatic distribution | Discuss compliance and efficiency benefits using Mitratech Mineral |
| Update or draft the Notice of Availability | Create and post a compliant notice if using the alternative furnishing method | Provide templates and share compliance updates from Mitratech Mineral |
| Support training and education | Advise teams on new rules, requests, and reporting steps | Provide access to Mitratech Mineral training resources and webinars |
| Create a 2026 reporting calendar | Schedule deadlines for validation, corrections, and filing | Share Mitratech Mineral’s automated calendar reminders and checklists |
| Review state-level healthcare reporting mandates | States such as CA, NJ, MA, RI, and DC have separate reporting requirements | Help clients leverage Mitratech Mineral’s state-specific compliance tools |
| Maintain documentation and records | Retain ACA records for at least six years | Share Mitratech Mineral’s resources and remind clients they have access to the HR Experts |
| Monitor IRS guidance | Watch for tax year forms and updates IRS AIR system down time | Share Mitratech Mineral Experts insights and alerts with clients |
Don’t Wait Until January
Open enrollment is the perfect time to clean and verify your ACA data. Read our blog Don’t Wait Until January: Why Open Enrollment Is the Best Time to Clean Your ACA Data to learn how early preparation sets the stage for accurate reporting.
Discover how aligning benefits enrollment with data validation helps employers correct errors, confirm eligibility, and avoid last-minute filing stress.
📘 Read Now: Don’t Wait Until January – Why Open Enrollment Is the Best Time to Clean Your ACA Data
Advice for Brokers: How to Support Clients During ACA Reporting Season
- Position ACA compliance as a value-add service.
Brokers can stand out as trusted advisors by helping clients simplify ACA reporting through tools such as the Mitratech Mineral ACA Reporting Hub. - Recommend the right compliance technology.
Direct clients toward integrated solutions that simplify form creation, data validation, and electronic filing. - Communicate early.
Share Mitratech Mineral’s reporting timelines and resources with clients well before the filing season begins. - Educate HR and payroll teams.
Use Mitratech Mineral training modules or webinars to help clients avoid reporting errors. - Audit client data proactively.
Encourage clients to use Mitratech Mineral’s validation tools to identify missing or mismatched data early. - Stay informed.
Subscribe to Mitratech Mineral updates so you can alert clients to new IRS guidance or deadline changes.
Getting Clients ACA-Ready
Want to help your clients prepare early for the 2026 reporting season? Read our blog What Brokers Should Be Doing Now to Get Clients ACA-Ready.
Discover practical steps brokers can take today to help employers organize data, stay ahead of ACA changes, and strengthen client relationships.
📘 Read Now: What Brokers Should Be Doing Now to Get Clients ACA-Ready
Why It Matters for Brokers and Employers
- Avoid penalties: Timely, accurate filing prevents costly fines.
- Reduce errors and rejections: Clean data ensures smoother submissions and fewer corrections.
- Build stronger relationships: Brokers who simplify ACA compliance become trusted advisors.
- Differentiate your offering: Partnering with Mineral allows brokers to bring modern compliance technology and expertise to every client.
Pro Tip: The Mitratech Mineral ACA Reporting Hub provides brokers and employers with a single, secure platform to manage ACA compliance from start to finish, including data accuracy, form generation, electronic submission, and expert-backed support.
Compliance is complex. Your solution doesn’t have to be.
Whether you are a broker guiding clients or an employer managing filings, the Mitratech Mineral ACA Reporting Hub gives you everything you need for a confident, penalty-free reporting season.