ACA Reporting Requirements for 2026: Employer Deadlines, Penalties and Compliance Tips

ACA Reporting Requirements for 2026: Employer Deadlines, Penalties and Compliance Tips

Published On: October 22, 2026Categories: Business, PayrollTags: ,

As 2026 comes to a close, employers should take steps now to prepare for Affordable Care Act (ACA) reporting. Understanding your reporting obligations, reviewing employee data, and planning for upcoming deadlines can help your business stay organized and reduce the risk of costly compliance errors.

Whether your organization already uses ACA reporting services or is evaluating whether the requirements apply to your workforce, this guide explains who must comply, what employers need to report, important 2027 deadlines, and how Payentry can help simplify the process.

Who Must Comply With the Affordable Care Act?

The Affordable Care Act (ACA) includes employer shared responsibility and information reporting requirements for organizations classified as Applicable Large Employers (ALEs).

An Applicable Large Employer (ALE) is generally an employer that averaged at least 50 full-time employees, including full-time equivalent employees, during the preceding calendar year. Employers must evaluate their workforce each year to determine whether they meet this threshold.

For example, employers generally use their 2025 workforce data to determine ALE status for 2026 and their 2026 workforce data to determine ALE status for 2027.

The IRS explains how to calculate employer size in its guide to determining whether an employer is an Applicable Large Employer.

What Are the ACA Requirements for Applicable Large Employers?

Applicable Large Employers generally must:

  • Offer qualifying health coverage: Offer minimum essential coverage to at least 95% of their full-time employees and their dependents to avoid the employer shared responsibility payment associated with failing to meet this offer threshold, subject to applicable rules.
  • Meet affordability requirements: Ensure that the employee’s required contribution for the lowest-cost self-only coverage option providing minimum value meets the applicable ACA affordability standard.
  • Provide minimum value: Offer coverage that meets the ACA’s minimum value requirements.
  • Track employee hours and eligibility: Maintain accurate records to determine which employees qualify as full-time under ACA rules.
  • Report coverage offers: File the required annual information returns with the IRS and furnish applicable employee statements.
  • Review payroll and benefits information: Ensure that relevant employee, eligibility, and coverage data are complete and consistent for reporting purposes.

ACA compliance can require coordination across payroll, benefits, HR, and other business functions. Monitoring changes throughout the year helps employers identify potential reporting issues before year-end.

What Is the Difference Between a Full-Time Employee and a Full-Time Equivalent Employee?

For ACA purposes, a full-time employee generally averages at least 30 hours of service per week or 130 hours of service in a calendar month.

A full-time equivalent employee (FTE) represents a combination of employees who individually are not full-time but whose hours collectively count toward the employer’s workforce-size calculation.

Importantly, part-time employees can affect whether an organization meets the 50-employee ALE threshold, even though full-time equivalent employees are not treated as full-time employees when determining who must receive an offer of coverage under the employer shared responsibility rules.

Employers approaching the threshold should review their workforce data carefully rather than relying solely on their total headcount.

What Are the ACA Reporting Deadlines for the 2026 Tax Year?

Employers reporting 2026 health coverage information must prepare to file the applicable forms in 2027.

Deadline Requirement
March 1, 2027 Paper filing of Forms 1094-C and 1095-C with the IRS
March 2, 2027 Furnish Form 1095-C to applicable full-time employees
March 31, 2027 Electronic filing of Forms 1094-C and 1095-C with the IRS

These dates reflect the calendar for 2026 reporting. Employers should confirm the applicable filing method, any extensions, and state-specific requirements before submitting their returns.

What Are Forms 1094-C and 1095-C?

Form 1094-C is the transmittal form that summarizes an Applicable Large Employer’s reporting and accompanies its Forms 1095-C when submitted to the IRS.

Form 1095-C reports information about an employer’s health coverage offers to applicable full-time employees. Depending on the employer’s health plan arrangement, it may also include information about coverage provided to enrolled individuals.

Employers should verify that employee information, coverage offers, affordability data, and other required fields are accurate before filing.

For official forms, instructions, and filing guidance, visit the IRS resources below:

Can Employers Request an Extension for ACA Reporting?

Employers can generally request an automatic 30-day extension to file information returns with the IRS by submitting Form 8809, Application for Extension of Time to File Information Returns, by the applicable deadline.

An extension to file with the IRS does not automatically extend the deadline to furnish employee statements. Employers should plan to meet both obligations on time.

See the IRS information return extension guidance for instructions and current requirements.

Do State ACA Reporting Deadlines Differ from Federal Deadlines?

Yes. Certain states and jurisdictions have their own health coverage reporting requirements, and their deadlines and filing procedures may differ from federal requirements.

Employers should determine whether they have obligations in states with individual health coverage mandates or related reporting rules. These include California, the District of Columbia, Massachusetts, New Jersey, and Rhode Island.

Consult the appropriate state agency for current requirements:

Employers with employees in multiple states should review each applicable jurisdiction rather than assume that federal reporting satisfies every state requirement.

What Are the ACA Penalties for Employers in 2026?

ACA employer shared responsibility payments can be significant. For the 2026 calendar year, the IRS has adjusted the applicable penalty amounts for inflation.

The two primary employer shared responsibility payment amounts are:

Type of potential violation 2026 annualized amount
Failure to offer required coverage $3,340 per applicable full-time employee, after the applicable reduction of up to 30 employees
Offering coverage that is unaffordable or does not provide minimum value $5,010 per full-time employee who receives a premium tax credit, subject to the applicable cap

These amounts are based on the IRS’s published 2026 adjustments under Internal Revenue Code Section 4980H. See IRS Revenue Procedure 2025-26.

Important: These are not automatic flat fines for every employer that makes a reporting error. Employer shared responsibility payments are calculated under specific rules, generally on a monthly basis, and require the applicable conditions to be met. Reporting errors may also result in separate information return penalties.

Employers should review both their coverage practices and their reporting processes to identify potential compliance issues before filing.

For additional details, consult the IRS guidance on employer shared responsibility provisions.

Is ACA Compliance Required if an Employer has Fewer than 50 Employees?

Generally, an employer that does not qualify as an Applicable Large Employer is not subject to the federal ACA employer shared responsibility and related Form 1094-C and Form 1095-C reporting requirements under Section 6056.

However, employers should not assume that having fewer than 50 employees automatically eliminates every ACA obligation. Other requirements may apply based on the employer’s health plan, state law, or other circumstances.

Employers should evaluate their workforce size using the IRS calculation method and review any other reporting requirements that apply to their organization.

Do Employers have to Report Health Coverage on Form W-2?

Generally, employers subject to the requirement must report the cost of applicable employer-sponsored health coverage in Box 12 of Form W-2 using Code DD.

The reporting requirement is generally optional for employers required to file fewer than 250 Forms W-2 for the preceding calendar year, subject to IRS rules and exceptions.

Reporting the cost of health coverage on Form W-2 is informational and does not, by itself, make the reported amount taxable to the employee.

Review the IRS guidance on Form W-2 reporting of employer-sponsored health coverage for details.

How Can Employers Prepare for ACA Reporting?

The most effective approach to ACA compliance is to maintain accurate data throughout the year rather than wait until filing season to review an entire calendar year’s records.

Use the following checklist to prepare for 2026 year-end reporting.

  • Confirm your ALE status. Review employee and full-time equivalent counts to determine whether ACA employer requirements apply.
  • Review employee hours. Monitor hours of service and employee status to identify potential eligibility changes.
  • Verify coverage information. Review coverage offers, effective dates, employee contributions, and applicable affordability information.
  • Reconcile payroll and benefits data. Confirm that employee records and coverage details are consistent across systems.
  • Review reporting data early. Identify missing information, discrepancies, and changes that may affect Form 1095-C.
  • Prepare employee statements. Confirm the information required for Forms 1095-C and plan for timely delivery.
  • Confirm filing responsibilities. Establish who will prepare, review, and submit the IRS returns.
  • Check state requirements. Identify additional reporting obligations and deadlines for every applicable jurisdiction.
  • Keep records organized. Maintain supporting documentation and records needed to substantiate coverage offers and reporting decisions.

December should be a time for final review and reconciliation, not the beginning of the entire compliance process. Addressing data issues earlier can help make year-end reporting more manageable.

How Payentry Helps Simplify ACA Reporting

ACA reporting involves multiple requirements, employee records, deadlines, and data checks. Having a reliable process and knowledgeable support can make a meaningful difference.

Payentry’s ACA services help employers manage reporting requirements with a more streamlined process and dedicated support.

Because your payroll and employee information is already maintained in Payentry, our ACA service builds on the data you are using today. This can help reduce reliance on separate spreadsheets, minimize manual handoffs, and make it easier to review information before filing.

With Payentry’s ACA services, you receive support that includes:

  • ACA reporting forms: Our dedicated ACA team generates Forms 1095-C for applicable employees.
  • IRS filing support: Our team files Form 1094-C with the IRS on your behalf as part of the service.
  • Secure employee delivery: Employee forms are delivered securely.
  • Monthly reminders: Stay informed about important reporting tasks and upcoming compliance considerations.
  • Built-in reporting: Monitor employee eligibility and review data to help identify potential discrepancies.
  • Dedicated customer service: Work with a team that understands the ACA reporting process and can help you navigate the steps involved.

Our goal is to help make ACA reporting more manageable, provide greater visibility into your data, and support a more organized year-end process.

Need Help with ACA Compliance or Reporting?

You do not have to navigate ACA reporting on your own.

Whether you are an existing Payentry client preparing for year-end, approaching the 50-full-time-equivalent employee threshold, or evaluating ACA reporting services for the first time, our team is ready to help you understand your options.

Contact our team of experienced experts to discuss your ACA reporting needs, review available reporting resources, and learn how our dedicated ACA team can support your business.

Let’s work together to prepare for year-end with greater confidence and a clearer path to meeting your reporting obligations.

Frequently Asked Questions About ACA Reporting

  1. Who is required to file ACA Forms 1094-C and 1095-C?

Generally, Applicable Large Employer members with an average of at least 50 full-time employees, including full-time equivalent employees, during the preceding calendar year must report information about health coverage offers under Section 6056. Special rules may apply to related employers and certain situations.

  1. What are the ACA reporting deadlines for 2026 coverage?

For 2026 coverage, employers generally must furnish Form 1095-C to applicable full-time employees by March 2, 2027. Paper filing of Forms 1094-C and 1095-C is due March 1, 2027, and electronic filing is due March 31, 2027.

  1. What is the difference between Form 1094-C and Form 1095-C?

Form 1094-C is the transmittal form used to submit an employer’s ACA reporting information to the IRS. Form 1095-C contains information about health coverage offers for applicable employees and is furnished to employees and filed with the IRS as required.

  1. What is the ACA 50-employee rule?

The ACA’s employer shared responsibility provisions generally apply to employers that averaged at least 50 full-time employees, including full-time equivalent employees, during the preceding calendar year. Employers calculate this threshold using specific monthly employee and hours-of-service rules.

  1. What are the ACA employer penalties for 2026?

For 2026, the adjusted annualized employer shared responsibility payment amounts are $3,340 for the failure-to-offer provision and $5,010 for the provision involving unaffordable or minimum-value coverage. The applicable payment depends on the employer’s circumstances and is subject to IRS calculation rules and limitations.

  1. Can an employer file ACA forms electronically?

Yes. Employers can file Forms 1094-C and 1095-C electronically. Generally, employers filing 10 or more information returns in aggregate must file electronically unless an exception or waiver applies. The electronic filing deadline for 2026 coverage is March 31, 2027.

  1. Can an employer get an extension for ACA reporting?

Employers can generally request an automatic 30-day extension to file information returns with the IRS using Form 8809, provided the request meets the applicable requirements. An extension to file does not automatically extend the deadline for furnishing employee statements.

  1. Does an employer with fewer than 50 employees need to file Form 1095-C?

Generally, employers that are not Applicable Large Employers are not required to file Forms 1094-C and 1095-C under the federal employer reporting rules in Section 6056. However, other coverage reporting requirements or state-specific obligations may apply.

  1. Does ACA reporting apply to employers with employees in multiple states?

Yes, federal ACA requirements may apply based on the employer’s workforce size regardless of whether employees work in one state or multiple states. Employers may also need to comply with additional state reporting requirements, depending on where employees live or receive coverage.

  1. How can Payentry help with ACA reporting?

Payentry’s ACA services include generating Forms 1095-C, filing Form 1094-C with the IRS on the client’s behalf, securely delivering employee forms, providing monthly reminders, and offering built-in reporting to help monitor eligibility and review data. Contact Payentry at 888.632.2940 or aca@payentry.com to learn more.

  1. Where can employers find official ACA reporting guidance?

The IRS provides official ACA reporting information, forms, instructions, and employer guidance through its ACA Information Center for Applicable Large Employers. Employers should also consult the relevant state tax or revenue agency for state-specific requirements.

Schedule a complimentary consultation and discuss how our experienced professionals can help you build a more confident, consistent approach to managing your employees.

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Disclaimer for ACA requirements: This blog is intended for general informational purposes and is not legal, tax, or benefits advice. ACA requirements, reporting procedures, and deadlines may change. Employers should consult current IRS guidance and qualified advisors regarding their specific circumstances.

*MPAY LLC dba Payentry (Company), is not a law firm. This article is intended for informational purposes only and should not be relied upon in reaching a conclusion in a particular area of law. Applicability of the legal principles discussed may differ substantially in individual situations. Receipt of this or any other Company materials does not create an attorney-client relationship. The Company is not responsible for any inadvertent errors that may occur in the publishing process.