What ACA reporting do employers have to complete each year?
Last updated October 2, 2026
Applicable large employers (50+ full-time equivalents) must file Forms 1094-C and 1095-C annually, furnishing 1095-Cs to employees, to report offers of coverage. Self-funded employers of any size also report covered individuals (Forms 1094-B/1095-B or Part III of the 1095-C).
The Affordable Care Act's reporting regime runs on two tracks:
- Employer mandate reporting (1094-C/1095-C): applicable large employers — 50 or more full-time equivalent employees — report month-by-month offers of coverage, affordability safe harbors, and enrollment for each full-time employee.
- Coverage reporting (1095-B or 1095-C Part III): self-funded plans report every covered individual, regardless of employer size.
Furnishing deadlines land in early March, with electronic IRS filing (now required for nearly all employers) by March 31. Errors and late filings carry per-form penalties that stack quickly across a workforce.
Most employers rely on payroll or benefits-administration vendors for the heavy lifting — but the filing obligation, and the penalty exposure, stay with the employer, which makes vendor oversight part of the fiduciary routine.
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