ACA Reporting Deadlines and Penalties Cheat Sheet

Ann Poland| January 12th, 2024

Benefits+, Compliance

Employers subject to Affordable Care Act (ACA) reporting under Internal Revenue Code Sections 6055 or 6056 should prepare to comply with reporting deadlines in early 2024. The following employers are subject to ACA reporting under Sections 6055 and 6056:

Employers with self-insured health plans (Section 6055 reporting); and
Applicable large employers (ALEs) with either fully insured or self-insured health plans (Section 6056 reporting). ALEs are employers with 50 or more full-time employees (including full-time equivalent employees) during the preceding calendar year.

Reporting Deadlines

The following chart provides the ACA reporting due dates for 2023 calendar year reporting. Note that there are no reporting obligations for non-ALEs without a plan or non-ALEs with fully insured plans (because non-ALEs are not subject to Section 6056 reporting and the carrier will complete Section 6055 reporting).

Action	Fully Insured ALEs Due Dates	Self-insured ALEs Due Dates	Self-insured Non-ALE Due Dates
Provide Forms 1095-C to Full-time Employees	March 1, 2024	March 1, 2024	N/A
Provide Forms 1095-B to Responsible Individuals	N/A	ALEs providing self-insured coverage to nonemployees may use either Form 1095-B or Form 1095-C to report coverage for those individuals and other family members covered under the plan by March 1, 2024.	March 1, 2024, if not using the alternative method of furnishing. Under this method, a reporting entity must post a clear and conspicuous notice on its website stating that responsible individuals may receive a copy of their statement upon request.
*File Forms 1094-C and 1095-C Electronically With the IRS**	April 1, 2024	April 1, 2024	N/A
*File Forms 1095-B and 1095-B Electronically With the IRS**	N/A	ALEs providing self-insured coverage to nonemployees may use either the B series forms or the C series forms to report coverage for those individuals and other family members covered under the plan by April 1, 2024.	April 1, 2024

*Beginning in 2024, reporting entities that file at least 10 returns during the calendar year must file electronically. Reporting entities must aggregate most information returns, such as Forms W-2 and 1099, to determine if they meet the 10-return threshold for mandatory electronic filing

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