10 Things You Need to Know About 2025 ACA Reporting Deadlines

The 2025 ACA reporting deadlines are fast approaching, and employers need to be prepared to file their returns on time. The Affordable Care Act (ACA) requires employers with 50 or more full-time employees to file annual reports detailing their health insurance coverage offerings. These reports are used by the Internal Revenue Service (IRS) to enforce the ACA’s employer mandate, which requires employers to offer affordable health insurance to their employees or face penalties. Employers also need to be aware of new reporting requirements that were added by the Tax Cuts and Jobs Act (TCJA). In this article, we will provide an overview of the 2025 ACA reporting deadlines and requirements.

The first ACA reporting deadline is February 28, 2026 for employers with 50 or more full-time employees. This deadline applies to the 2025 calendar year. Employers must file Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, which provides information about the health insurance coverage that was offered to employees during the year. Employers must also file Form 1095-B, Health Coverage, for each employee who was offered health insurance coverage. The second ACA reporting deadline is March 31, 2026 for employers with 50 or more full-time employees. This deadline applies to the 2025 calendar year and employers must file Form 1094-C, Transmittal of Health Coverage Information Returns, which transmits the Forms 1095-C and 1095-B to the IRS.

The TCJA added new ACA reporting requirements for employers with 50 or more full-time employees. Employers must now report the cost of health insurance coverage on employees’ W-2 forms. This information is used to calculate the individual mandate penalty, which is a tax penalty that applies to individuals who do not have health insurance coverage. The TCJA also requires employers to report the value of any non-cash fringe benefits, such as health insurance premiums, on employees’ W-2 forms. This information is used to calculate the employer’s payroll taxes. Employers need to be aware of these new reporting requirements and ensure that they are filing their returns correctly.

ACA Reporting Deadlines for Employers

The Affordable Care Act (ACA) requires employers with 50 or more full-time employees (FTEs) to file annual reports on the health insurance coverage they offer to their employees. These reports, known as the Employer Shared Responsibility Provision (ESRP) and Employer Mandate, help the IRS enforce the ACA’s requirement that employers provide health insurance to their employees or pay a penalty.

Deadlines for Employers with 50 or More FTEs

The ACA reporting deadlines for employers with 50 or more FTEs are as follows:

Form	Deadline
Form 1095-C	February 28th (March 31st if filing electronically)
Form 1095-B	February 28th (March 31st if filing electronically)
Forms 1094-C and 1094-B	April 1st (April 30th if filing electronically)

Employers must file these forms with the IRS and furnish copies to their employees by the deadlines listed above.

Forms 1095-C and 1095-B

Forms 1095-C and 1095-B report information about the health insurance coverage offered to employees and their dependents. Form 1095-C is for employers who offer self-insured health plans, while Form 1095-B is for employers who offer fully insured health plans.

Forms 1094-C and 1094-B

Forms 1094-C and 1094-B provide a summary of the information reported on Forms 1095-C and 1095-B, respectively. Employers must complete Form 1094-C if they file 250 or more Forms 1095-C. Employers must complete Form 1094-B if they file 250 or more Forms 1095-B.

Individuals’ ACA Reporting Responsibilities

ACA Reporting Role

Individuals are not obligated to report ACA information to the IRS. Health insurance companies and employers are accountable for furnishing this data to both the taxpayers and the government.

Filing an Exception

Individuals who are not covered by health insurance, or who are eligible for an exemption from the individual mandate, must file an exception with the IRS. This can be done by submitting Form 8965, Health Coverage Exemptions.

Reporting Responsibility	Filing Deadline	Filing Form
Individuals without health insurance	April 15th (May 15th with extension)	Form 8965
Individuals eligible for exemption	April 15th (May 15th with extension)	Form 8965

Consequences of Missing ACA Reporting Deadlines

Penalties for Employers

Failing to meet the ACA reporting deadlines can result in significant penalties for employers. The penalty for not filing the required forms on time is $260 per employee, up to a maximum of $3,900,000 per year. Additionally, employers may face penalties of $500 per employee for each day the return is late, up to a maximum of $2 million per year.

Penalties for Individuals

Individuals who fail to file the required forms on time may face a penalty of up to $500. This penalty applies to both individuals who are required to file Form 1095-A and those who are required to file Form 1095-B.

Other Consequences

In addition to the financial penalties, missing ACA reporting deadlines can also have other negative consequences. For example, employers who fail to file the required forms may be unable to claim the premium tax credit. Individuals who fail to file the required forms may be unable to access health insurance subsidies. Additionally, missing ACA reporting deadlines can damage an employer’s reputation and make it more difficult to attract and retain employees.

Penalty Type	Amount	Maximum
Employer Penalty for Late Filing	$260 per employee	$3,900,000 per year
Employer Penalty for Late Return	$500 per employee per day	$2 million per year
Individual Penalty for Late Filing	$500	N/A

Changes to ACA Reporting Requirements in 2025

4. New Reporting Requirements for Employers with Self-Funded Health Plans

Employers with self-funded health plans will face new reporting requirements under the ACA in 2025. These requirements include:

Reporting the total number of individuals covered under the plan, including employees, dependents, and retirees.
Reporting the total amount of premiums paid by the employer and employees.
Reporting the total amount of claims paid by the plan.

These new reporting requirements are intended to provide the IRS with more information about the coverage and costs of self-funded health plans. This information will be used to ensure that employers are complying with the ACA’s requirements and to identify areas where the law can be improved.

The IRS has not yet released final regulations on these new reporting requirements. However, employers should begin preparing for these changes now. Employers should work with their plan administrators and insurance carriers to ensure that they have the systems and processes in place to collect and report the required data.

Year	Reporting Deadline
2025	March 31, 2026

Guidance for Healthcare Providers on ACA Reporting

Forms and Filing Deadlines

The following table summarizes the forms and filing deadlines for 2025 ACA reporting:

Form	Filing Deadline
Form 1095-B	March 1, 2026
Form 1095-C	March 1, 2026

Who Must File

All employers, insurers, and other entities required to provide health insurance coverage under the ACA must file ACA returns.

Electronic Filing Requirements

All ACA returns must be filed electronically through the IRS AIR system.

Access to Code Lists

Code lists, which provide the codes needed to complete ACA forms, are available on the IRS website.

Special Rules for Small Employers

Small employers may file a combined annual return for Forms 1095-B and 1095-C.

Penalties for Noncompliance

Failure to comply with ACA reporting requirements can result in significant penalties.

Additional Resources

The IRS website provides additional resources, including FAQs and training materials, to assist with ACA reporting.

Common Errors to Avoid

Some common errors to avoid when filing ACA returns include:

Incorrect or incomplete information
Using incorrect code lists
Filing late or submitting paper returns

ACA Reporting and the State Health Insurance Exchanges

Who Must File ACA Reports?

Employers with 50 or more full-time or full-time equivalent employees (FTEs) are required to file ACA reports.

What Information Is Collected?

ACA reports collect information about employer-sponsored health coverage, including the number of employees offered coverage, the number of employees enrolled in coverage, and the total cost of coverage.

When Are ACA Reports Due?

ACA reports are due annually by March 31st for the previous calendar year. Reporting can be done electronically or by paper.

Consequences of Non-Compliance

Employers who fail to file ACA reports or file incomplete reports may be subject to penalties.

State Health Insurance Exchanges

State Health Insurance Exchanges (HIEs) are online marketplaces where individuals and small businesses can shop for health insurance plans.

The Role of Exchanges in ACA Reporting

HIEs play a role in ACA reporting by collecting and reporting data on the number of individuals and small businesses who have enrolled in health insurance plans through the exchanges.

Employer Reporting Threshold for Exchanges

Employers with 50 or more FTEs are required to report to both the IRS and HIEs on the coverage offered to their employees.

HIE Reporting Threshold for Individuals and Small Businesses

HIEs are required to report on individuals and small businesses who have enrolled in health insurance plans through the exchanges.

Consequences of Non-Compliance for Exchanges

Exchanges that fail to file ACA reports or file incomplete reports may be subject to penalties.

Future Trends in ACA Reporting

1. Automation and Streamlining

Technology advancements are driving automation and streamlining in ACA reporting, reducing manual processes and increasing efficiency. Employers can now use software and online platforms to gather, process, and submit ACA information.

2. Integration with Payroll Systems

ACA reporting is increasingly integrated with payroll systems, making it easier for employers to track and report employee information. This integration eliminates the need for manual data entry and reduces the risk of errors.

3. Mobile Accessibility

ACA reporting tools are becoming increasingly mobile-friendly, allowing employers to access and manage their reporting requirements on the go. This flexibility enhances convenience and facilitates timely reporting.

4. Real-Time Compliance Tracking

Advanced reporting systems provide real-time compliance tracking, enabling employers to monitor their ACA obligations and identify potential issues early on. This allows for proactive action to address compliance challenges.

5. Cloud-Based Storage

Cloud-based storage solutions provide secure and accessible repositories for ACA reporting information. Employers can easily store, retrieve, and share ACA data securely, reducing the risk of data loss.

6. Enhanced Data Validation

Automated data validation tools help employers identify and correct errors before submitting ACA reports. These tools ensure data accuracy and reduce the likelihood of rejections or penalties.

7. Personalized Reporting

Reporting platforms are becoming more personalized, providing customized reporting options based on employer size and industry. This tailored approach simplifies the reporting process and ensures compliance with specific requirements.

8. AI-Driven Insights

Artificial intelligence (AI) is being utilized to analyze ACA reporting data and provide valuable insights. Employers can use these insights to identify trends, improve compliance, and optimize their reporting processes.

9. Blockchain and Data Security

Blockchain technology is gaining traction in ACA reporting, enhancing data security and transparency. This technology ensures the integrity of ACA data and reduces the risk of fraud and data breaches.

10. Continuous Regulatory Evolution

ACA regulations are continuously evolving, and reporting requirements may change over time. Employers should stay informed about these changes and adapt their reporting processes accordingly to ensure ongoing compliance.

2025 ACA Reporting Deadlines

The Affordable Care Act (ACA) requires employers and health insurers to report certain information about health coverage to the government. The reporting deadlines for 2025 are as follows:

For employers with 50 or more full-time employees: March 31, 2026
For employers with fewer than 50 full-time employees: May 31, 2026
For health insurers: March 31, 2026

Employers and health insurers must file their reports electronically using the IRS’s ACA Information Returns (AIR) system. The AIR system is available at https://www.irs.gov/ ACA-Information-Returns.