For calendar year 2024, an Applicable Large Employer (ALE) must furnish Form 1095-C to eligible employees by March 3, 2025. The ACA deadline for filing paper Forms 1094-C and 1095-C with the IRS is February 28, 2025. The due date for electronic filing is March 31, 2025. These are expected due dates. The IRS had not issued final due dates at the time this article was updated. The affordability rate for plan years beginning in 2025 is 9.02% (an increase from 8.39% for plan years beginning in 2024).
Businesses subject to ACA requirements for tracking and reporting have several deadlines to meet if they want to be in ACA compliance. There are deadlines for furnishing forms to employees and for filing forms to the IRS. The IRS permanently provided an automatic 30-day extension from the January 31 due date for ALEs to provide forms 1095-C to applicable employees, which means no additional extensions are available.
The deadline for ACA filing of all paper forms with the IRS remains February 28. However, the deadline is March 31 if filing electronically. The due date is the next business day if it falls on a weekend or legal holiday. It should be noted that all employers that file a combined total of 10 or more information returns, including Forms 1094-C and 1095-C, must file the forms electronically.
Managing Affordable Care Act Reporting Requirements Due in 2025
Paychex | Oct 2024
IRS Links to Tax Year 2024 Forms and Instruction Manuals
Instruction Manuals
1094-C & 1095-C
1094-B & 1095-B
Forms
1095-C
1095-B
The critical 2025 filing deadlines (for 2024 coverage) are as follows:
Paper filing with IRS Feb 28
1095 forms delivered to employees Mar 3
Electronic filing with IRS Mar 31***
*** NOTE: Beginning in 2024, employers that file at least 10 returns during the calendar year must file electronically.
Additional Articles
Everything Employers Need to Know About 2025 ACA Reporting
RPI | Dec 2024
Employer’s Guide to ACA Reporting: 2024 Forms and Instructions
The Fedeli Group via Barrow | Nov 2024
ACA Reporting Requirements in 2025
Newfront | Oct 2024
Related Reading
A common fact pattern that frequently results in ACA reporting errors is the employee who moves from a full-time position to a part-time position mid-year. Must plan sponsors continue to offer this part-time employee health coverage? Doesn’t the ACA only require employers to offer health coverage to their full-time employees? The answers to these questions depend on which measurement methodology the employer uses to calculate full-time employee/full-time equivalent (“FTE”) status.
ACA Compliance When Employees Move from Full-Time to Part-Time Mid-Year
Verrill | Feb 2024
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