ACA reporting deadlines come around every winter like clockwork. That’s the good news and the bad news. The dates rarely shift, which means you can plan for them well in advance. But because they’re so predictable, they’re also easy to push aside until suddenly it’s February and your data isn’t ready.
If you’re an Applicable Large Employer, the 2026 coverage year forms are due in early 2027. Below is a rundown of the federal deadlines, the state-level obligations that may apply on top of them, and what you can do now to avoid a last-minute scramble.
The federal deadlines
Three dates matter for the 2026 reporting year:
- March 2, 2027 — Furnish Form 1095-C to each full-time employee
- March 1, 2027 — Paper-file Forms 1094-C and 1095-C with the IRS (if eligible to file on paper)
- March 31, 2027 — Electronically file Forms 1094-C and 1095-C with the IRS
The furnishing deadline of March 2 reflects an automatic extension from the standard January 31 date. The IRS has confirmed that no further extensions will be granted, so this is your hard stop for getting forms to employees.
The paper and electronic filing deadlines follow their usual pattern: February 28 for paper (adjusted to the next business day, which lands on March 1 in 2027) and March 31 for electronic filing.
Two structural changes worth noting
The deadlines themselves are familiar, but the filing landscape has shifted in two ways that affect how you submit:
Electronic filing is required for most employers. If your organization files 10 or more information returns total — and that’s 1095-C forms, W-2s, 1099s, and other returns combined — you must file electronically. Paper is no longer an option for most ALEs. The 10-return threshold applies in the aggregate, so even a small number of 1095-C forms can trigger the e-filing requirement if your total return volume crosses that line.
The FIRE system is being retired. For the 2026 tax year, the IRS is shutting down the FIRE (Filing Information Returns Electronically) system. The Information Returns Intake System (IRIS) becomes the sole intake system for information returns starting in filing season 2027. ACA returns continue to go through the ACA Information Returns (AIR) system, which requires a Transmitter Control Code (TCC). If you’re filing yourself or through a vendor, confirm your TCC is active well before March 31.
State-specific reporting deadlines
Federal compliance is only part of the picture. Several states have their own individual health insurance mandates with employer reporting requirements that kick in when you have employees living in that state. These obligations are separate from federal filing, and the rules continue to evolve.
California Employers must furnish Form 1095-B or 1095-C to California residents enrolled in their plan and file 1094/1095 data with the Franchise Tax Board.
- Furnish to employees: January 31, 2027 (no penalty if furnished by the federal deadline of March 2)
- State filing: March 31, 2027, with an automatic penalty-free extension through May 31, 2027
New Jersey Employers must furnish Form 1095 to New Jersey residents and file with the Division of Taxation.
- Furnish to employees: March 2, 2027
- State filing: March 31, 2027
Rhode Island Employers must furnish Form 1095-B/C to Rhode Island residents and file with the Division of Taxation.
- Furnish to employees: March 2, 2027
- State filing: March 31, 2027
Massachusetts Massachusetts has operated its own individual mandate since 2006. Employers and carriers must provide Form MA 1099-HC to residents and report electronically through MassTaxConnect.
- Furnish to employees: January 31, 2027
- State filing: March 31, 2027 (electronic only; paper is not accepted)
Washington, D.C. D.C. requires employers to furnish Form 1095 to residents and file electronically with the Office of Tax and Revenue. The filing deadline is set at 30 days after the federal deadline, making it the latest among the mandate jurisdictions.
- Furnish to employees: March 2, 2027
- State filing: April 30, 2027
Vermont Vermont has an individual mandate but does not currently impose an employer reporting requirement. Federal ACA reporting still applies for Vermont residents.
State rules change. Legislative updates, regulatory guidance, and administrative rule changes can shift deadlines, forms, and filing methods. If you have employees in any of these states, verify the current requirements as filing season approaches. A handful of other states — including Connecticut, Minnesota, and Maryland — have considered individual mandates in the past, and new states may adopt reporting requirements going forward.
Where employers get tripped up
Most ACA reporting problems fall into a few recurring categories:
- Data scattered across systems. The information needed for 1094-C and 1095-C forms typically lives in payroll, benefits administration, and HRIS platforms. Aggregating it accurately is one of the biggest challenges.
- Incorrect indicator codes. Line 14 and Line 16 safe harbor codes are the most common source of reporting errors. Getting them wrong can trigger IRS penalty notices.
- Missed furnishing deadline. The March 2 extension is the only one available. There is no additional extension for getting forms to employees.
- Missing TCC. Without a valid Transmitter Control Code, you can’t e-file through AIR. Discovering this in March is too late.
- Self-funded plan complexity. Self-funded plans require Section III of Form 1095-C for each employee, adding another layer of data and validation.
- Overlooking state obligations. Federal compliance doesn’t cover you in states with their own mandates. Each state has its own forms, deadlines, and filing systems, and missing them can carry separate penalties.
What to do now
The employers who handle ACA reporting cleanly are the ones who start in the fall, not in late winter. Between now and year-end:
- Compile and validate employee data — eligibility, elections, coverage months, and offer details
- Keep your employee roster current with new hires and terminations so year-end data is accurate
- Verify your e-filing credentials and TCC are active
- Review indicator code assignments for correctness
- Confirm whether self-funded plan obligations apply (Section III)
- Identify employees in mandate states and map out the state-specific requirements for your workforce
ACA File by ebm
Reporting is complex, detail-heavy, and unforgiving when something is wrong — and state requirements add another layer on top of the federal obligations. ACA File is our standalone reporting solution built to handle the entire process.
The workflow is straightforward. You start with a Microsoft Excel workbook where you enter eligibility and election information for your employee population. Throughout the year, you add new hires and mark terminated employees as they come and go. After year-end, we load the workbook into our system and generate your 6055/6056 reporting. Built-in validation flags missing information and potential errors before they become filing problems. We then electronically file your 1094-C with the IRS and print and mail 1095-C forms directly to your employees via USPS.
ACA File handles completion of Forms 1094-C and 1095-C, Section III for self-funded plans, monthly employee counts and form counts for 1094-C, indicator code determination, plan effective date assignment, electronic filing with the IRS, and printing and mailing of 1095 forms to employee addresses. An optional database flush is available after reporting is complete.
Get ahead of the 2027 filing season
The deadlines will be here before they feel close. Rather than pulling data together at the last minute, second-guessing indicator codes, and hoping your filing credentials come through in time, let our team take it off your plate. ACA File by ebm covers the full process — from data compilation through IRS e-filing and employee mailings — in one interface.
Learn more about ACA File, schedule a discovery call, or reach out to our team. We’ll help you meet every deadline with confidence.
