ACA reporting season starts in March, but employers must reconcile 2026 coverage data before year-end
Key points
- ALEs with 50 or more full-time or equivalent employees must file Forms 1094-C and 1095-C for the 2026 plan year
- Based on the IRS's usual 30-day extension pattern, forms are expected to reach employees by March 2, 2027 and the IRS by March 31
- Full-time status, offer dates and affordability codes should be reconciled before December 31
Applicable large employers (ALEs) with 50 or more full-time employees or equivalents must file Forms 1094-C and 1095-C for the 2026 plan year. Based on the IRS's usual 30-day extension pattern, forms are expected to reach employees by March 2, 2027, and the IRS electronically by March 31, with final dates set in IRS instructions. The article says data problems in full-time status, offer dates and affordability codes built up during 2026 and should be reconciled before the December 31 year-end. This is for reference only and does not constitute legal advice.
What employers should do
- Reconcile full-time status, offer dates and affordability codes before December 31
- Watch IRS instructions for the final 1094-C and 1095-C deadlines for the year
Policy details
- Jurisdiction
- Federal (United States)
- Status
- In effect
- Effective date
- —
- Employers covered
- Applicable large employers (50 or more full-time or equivalent employees)
- Official source
- View official source ↗
Original report: Insurance Business ↗Edited with AI assistance. Facts are based on official sources and original reports. For information only; not legal, immigration or insurance advice.