ACA reporting deadlines: what applicable large employers actually have to do

If you averaged 50 or more full-time employees including full-time equivalents last year, you are an applicable large employer, and ACA reporting is not optional. Here is the whole calendar in one place.

Furnishing Form 1095-C to employees

The statutory deadline is January 31. A permanent automatic 30-day extension applies, which moves it to early March in practice. For the 2025 calendar year, the IRS instructions set the furnishing deadline at March 2, 2026.

You do not have to request that extension. It is automatic.

Filing Forms 1094-C and 1095-C with the IRS

The filing deadline is February 28 on paper, or March 31 if filing electronically. For the 2025 calendar year that meant March 2, 2026 on paper, or March 31, 2026 electronically.

Note that the furnishing deadline and the paper filing deadline land in the same week. Those are two separate obligations, and employers regularly meet one and miss the other.

You almost certainly have to file electronically

The electronic filing threshold is 10 or more information returns in a calendar year — and that is counted in aggregate, not per form type. Your W-2s and 1099s count toward it.

An employer with 8 employees files 8 W-2s and 8 1095-Cs. That is 16 returns in aggregate, so electronic filing is required.

In practice, if you are an ALE at all, you are over the threshold. Filing goes through the IRS ACA Information Returns system.

The alternative furnishing method

Since the Paperwork Burden Reduction Act, you may skip mailing a 1095-C to every employee and instead furnish on request. The relief is real, but it is conditional, and the conditions have dates attached:

• Post a clear, conspicuous, and accessible notice on your website telling employees they may request their statement.
• The notice must include an email address, a physical mailing address, and a telephone number for making the request.
• Use plain, non-technical language and a font size that actually draws attention.
• For the 2025 tax year, the notice had to be posted by March 2, 2026 and retained through October 15, 2026.
• When an employee requests a statement, furnish it by the later of January 31 of the filing year or 30 days after the request.

Miss the posting window and you have not validly used the alternative method — which means you were required to furnish to everyone, and you did not.

The part that decides whether any of this goes smoothly

The forms are the easy part. The codes on a 1095-C come out of twelve months of eligibility records: measurement periods, waiting periods, every offer of coverage, every waiver, and affordability under whichever safe harbor you use.

If the eligibility data is right, the filing is mechanical. If it is not, January becomes an archaeology project. That is the real argument for having one team hold both eligibility administration and reporting — when the IRS asks why an employee shows a particular code, the answer exists.

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