As 2026 progresses, deadlines are fast approaching for employers with ACA reporting obligations. Whether you’re managing a self-insured plan or you’re an applicable large employer (ALE), staying compliant with IRS reporting requirements is critical to avoiding penalties and maintaining good standing.

This post breaks down the essential deadlines, requirements, and procedural updates you need to know to navigate ACA reporting for the 2025 calendar year with confidence.

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Who Must Comply with ACA Reporting?

The following employers are subject to ACA reporting:

• Employers with self-insured health plans (Section 6055 reporting)
• Applicable large employers (ALEs) with either fully insured or self-insured health plans (Section 6056 reporting)

ALEs are employers with 50 or more full-time employees (including full-time equivalent employees) during the preceding calendar year. ALEs with self-funded plans must comply with both reporting obligations. To simplify reporting, the IRS allows ALEs with self-insured plans to use a single combined form to report information required under both Sections 6055 and 6056.

Critical Deadlines for 2026

For the 2025 calendar year, covered employers must adhere to the following deadlines:

March 2, 2026: Website Notice Deadline

Employers must post a clear, conspicuous, and easily accessible notice on their website informing individuals that they may request a copy of Forms 1095-B or 1095-C. The notice must remain posted through Oct. 15, 2026.

Statements must be furnished by the later of Jan. 31, 2026, or 30 days after the date of the request.

Alternatively, employers may provide Forms 1095-B or 1095-C directly to individuals by March 2, 2026 instead of posting the notice.

March 31, 2026: IRS Electronic Filing Deadline

Employers must file returns electronically if they file at least 10 returns during the calendar year.

Understanding Section 6055 and 6056 Reporting

ACA reporting falls into two categories based on employer size and type of coverage offered:

• Section 6055 applies to providers of minimum essential coverage (MEC), including health insurance issuers and employers with self-insured plans. These entities generally use Form 1094-B and Form 1095-B.
• Section 6056 applies to ALEs (50 or more full-time employees, including equivalents). ALEs use Form 1094-C and Form 1095-C to report coverage offered to full-time employees.

ALEs with self-insured plans file Forms 1094-C and 1095-C using the combined reporting method.

Electronic Filing Requirements

The electronic filing threshold was lowered significantly in recent years.

For returns required to be filed on or after Jan. 1, 2024, the threshold is 10 or more returns (previously 250).

Important clarifications:

• The 10-return requirement applies in the aggregate across certain information returns, including Forms W-2 and 1099.
• Entities may request a hardship waiver, though the IRS encourages electronic filing even below the threshold.
• Electronic filings must follow IRS XML Schemas and Business Rules rather than paper formatting instructions.
• See IRS Publications 5164 and 5165.

Electronic filings are submitted through the ACA Information Returns (AIR) Program.

Alternative Furnishing Method

Reporting entities are no longer required to automatically furnish Forms 1095-B and 1095-C to individuals. Instead, they may post a website notice explaining how individuals can request a copy.

To satisfy furnishing requirements for 2025 statements (issued in 2026), the notice must:

• Be clear, conspicuous, and accessible, and include an email address, mailing address, and phone number
• Be posted by March 2, 2026
• Remain posted through Oct. 15, 2026

Requests must be fulfilled by Jan. 31 of the following year or 30 days after the request, whichever is later.

Statements may also be furnished electronically if individuals have provided affirmative consent at any time at any prior time.

This alternative method can significantly reduce administrative burden.

Filing Extensions

Employers may receive an automatic 30-day extension to file by completing and filing Form 8809 by the due date of the return. Additional extensions may be

available under certain hardship conditions.

Your Next Steps

With March deadlines right around the corner, now is the time to ensure your organization has the processes, systems, and knowledge in place to meet your ACA reporting obligations.

Whether you’re navigating these requirements for the first time or looking to streamline your existing compliance processes, having the right information and support can make all the difference.

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This material is provided for general informational purposes only and is not legal or tax advice. Consult qualified counsel regarding your specific situation.