For employers subject to the Affordable Care Act (ACA), staying compliant with reporting requirements is non-negotiable. With 2026 due dates now upon us, it is time to prepare for distributing Forms 1095-C or 1095-B to employees and filing with the IRS.

Forms 1095-B are used by small employers sponsoring a self-insured or level-funded health plan. Although small employers (defined by the law as those employing fewer than 50 full-time, including full-time equivalent, employees in the preceding calendar year) are not subject to the ACA employer mandate, they are still subject to the reporting requirements because their health plan is not fully insured. Small employers are only required to report on enrolled individuals.

Forms 1095-C are used by large employers (defined by the law as those employing 50 or more full-time, including full-time equivalent, employees in the preceding calendar year) regardless of their health plan funding. These forms provide essential information about health coverage offered to employees (regardless of whether an employee enrolled or declined coverage) and are critical for demonstrating compliance with the ACA’s employer mandate.

Missing these deadlines can lead to potential costly penalties and compliance headaches.

Key ACA Reporting Deadlines for 2026

Here are the critical dates you need to mark on your calendar for reporting on the 2025 tax year:

• March 2, 2026: Deadline for furnishing Form 1095-C to employees.
  Employers must provide their employees with a copy of Form 1095-B/C
• March 2, 2026: Deadline for paper filing with the IRS. Employers filing fewer than 10 forms (aggregated with other forms, such as W-2, 1099) may submit paper forms to the IRS. Note: Paper filing is only an option for small employers below the e-filing threshold.
• March 31, 2026: Deadline for electronic filing with the IRS. Employers submitting 10 or more forms (aggregated with other forms, such as W-2, 1099) are required to file electronically. The extra time provided for electronic filing gives employers a reprieve, but it’s essential to plan ahead and avoid last-minute delays.

Employers concerned they may not make the electronic filing deadline (March 31, 2026) can file Form 8809, Application for Extension of Time to File Information Returns for a 30 day extension.

Penalties for Missing ACA Reporting Deadlines

Failing to meet ACA reporting deadlines can result in hefty penalties:

1. Late Furnishing to Employees: Employers can be fined $340 per form for not providing Form 1095-B/C to employees by March 2, 2026. Fines escalate for intentional disregard.
2. Late Filing with the IRS: Employers can be fined $340 per form for not filing a complete return to the IRS by March 31, 2026. Fines escalate for intentional disregard.

Checklist to Stay on Track for ACA Reporting in 2025

Use this checklist to ensure timely and accurate submissions:

1. Verify Employee Data: Review employee names, SSNs, and coverage details for accuracy.
2. Select Your Filing Method: Determine whether you’ll file on paper (if eligible) or electronically. Ensure you have the necessary software for electronic submissions.
3. Monitor Deadlines: Set reminders for all IRS deadlines to have plenty of time to meet them.
4. Test Your Process: If filing on your own, conduct a test submission through the IRS AIR system to identify potential errors before the official filing.
5. Leverage Technology: Use an ACA compliance software solution to automate form generation, validation, and submission.
6. Train Your Team: Ensure HR, payroll, and benefits teams understand the reporting requirements and deadlines.
7. Work with Experts: Consider outsourcing ACA compliance to a trusted vendor if your internal resources are limited.

Conclusion

ACA reporting doesn’t have to be overwhelming—preparation is key. By understanding the deadlines, filing methods, and potential pitfalls, employers can stay compliant and avoid penalties. With the reporting season underway, now is the time to finalize your plans, gather your data, and ensure you’re ready to meet the 2026 deadlines.

Need help simplifying your ACA reporting process? Mitratech’s Mineral Platform offers an ACA Reporting Tool designed to streamline your reporting and keep your business on track.