Employers subject to Affordable Care Act (ACA) reporting under Internal Revenue Code Sections 6055 and 6056 should prepare to comply with reporting deadlines for calendar year 2025. In general, self-insuring employers are subject to Section 6055, and applicable large employers (ALEs)—those with 50 or more full-time employees during the prior calendar year—are subject to Section 6056. There are no reporting obligations for non-ALEs without a plan or non-ALEs with fully insured plans (as the carrier will complete Section 6055 reporting).
For the 2025 calendar year, covered employers must:
- File returns with the IRS electronically by March 31, 2026. Employers that file at least 10 returns during the calendar year must file electronically.
- Post a clear, conspicuous and easily accessible notice on their websites by March 2, 2026, informing individuals that they may request a copy of Forms 1095-B or 1095-C. The notice must be retained until Oct. 15, 2026, and statements must be furnished to any requesting individual by the later of Jan. 31, 2026, or 30 days after the date of the request. Alternatively, if a reporting entity chooses not to post the notice online, it may instead provide Forms 1095-B or 1095-C directly to individuals by March 2, 2026.
The following employers are subject to ACA reporting:
- Employers with self-insured health plans (Section 6055 reporting)
- ALEs with either fully insured or self-insured health plans (Section 6056 reporting)
Annual Filing Deadline
Generally, forms must be filed with the IRS annually, no later than March 31 of the year following the calendar year to which the return relates. Employers may receive an automatic 30-day extension to file with the IRS by completing and filing Form 8809 by the due date of the return. Additional extensions of time to file may also be available under certain hardship conditions.
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