The Affordable Care Act requires applicable large employers (ALEs) – generally those with 50 or more full-time employees – to report information to the IRS and to their full-time employees about their compliance with the employer shared responsibility (pay or play) provisions and the health care coverage they have offered (or did not offer).
Self-insured employers (regardless of size) have additional reporting responsibilities that apply to health coverage providers.
2025 filing deadlines for 2024 coverage are as follows:
|
ACA Requirement (Fully Insured ALE’s) |
Deadline |
|
Provide Form 1095-C to Full-Time Employees |
March 3, 2025* |
|
File Forms 1094-C &1095-C with the IRS |
March 3, 2025* |
|
ACA Requirement (Self-Insured ALE’s) |
Deadline |
|
Provide Form 1095-C to Full-Time Employees |
March 3, 2025* |
| Provide Form 1095-B to Responsible Individuals (may be the primary insured, employee, former employee, or other related person named on the application) |
ALEs providing self-insured coverage to non-employees may use either Form 1095-B or Form 1095-C to report coverage for those individuals and other family members covered under the plan, by March 3, 2025. |
|
File Forms 1094-B & 1095-B with the IRS |
ALEs providing self-insured coverage to non-employees may use either the B series Forms or the C series Forms to report coverage for those individuals and other family members covered under the plan, by March 31, 2025* |
|
ACA Requirement |
Deadline |
|
Provide Form 1095-B to Responsible Individuals (may be the primary insured, employee, former employee, or other related person named on the application) |
March 3, 2025, if not using the alternative method of furnishing. Under this method, a reporting entity must post a clear and conspicuous notice on its website stating that responsible individuals may receive a copy of their statement upon request. |
|
File Forms 1094-B & 1095-B with the IRS |
March 31, 2025* |
Forms & Instructions
The following Internal Revenue Service (IRS) forms and instructions are available for 2024 calendar year reporting:
- Large Employer Reporting (Section 6056)
- Form 1094-C and Form 1095-C (and instructions)
- Minimum Essential Coverage (MEC) Reporting (Section 6055)
Form 1094-B and Form 1095-B (and instructions)
*Beginning with 2024 calendar year reporting employers may use the alternative method of furnishing forms 1095-C to employees. Under this method, they must post a clear and conspicuous notice on their website stating that responsible individuals may receive a copy of their statement upon request.
For updated 2025 ACA reporting details you can view our ACA Reporting Guide.
**Reporting entities that file at least 10 returns during the calendar year must file electronically.