2026 ACA Reporting Requirements

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 2026. This guide provides comprehensive information on deadlines, covered employers, reporting requirements, and penalties for the 2025 calendar year.

Key Deadlines for 2026

For the 2025 calendar year, covered employers must:

• File Returns with the IRS: March 31, 2026 (electronic filing required for employers filing at least 10 returns during the calendar year)

• Post Website Notice or Furnish Statements: March 2, 2026

  • Post a clear, conspicuous, and easily accessible notice on their websites informing individuals that they may request a copy of Forms 1095-B or 1095-C

  • The notice must be retained until October 15, 2026

  • Statements must be furnished to requesting individuals by the later of January 31, 2026, or 30 days after the date of the request

Alternative: Instead of posting the notice online, reporting entities may provide Forms 1095-B or 1095-C directly to individuals by March 2, 2026.

Who Must Report

The following employers are subject to ACA reporting:

• Employers with self-insured health plans (Section 6055 reporting)

• 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.

Important: ALEs with self-funded plans are required to comply with both Section 6055 and Section 6056 reporting obligations. However, the IRS allows these employers to use a single combined form (Forms 1094-C and 1095-C) to simplify the reporting process.

Understanding Section 6055 and 6056 Reporting

Section 6055 Reporting

Section 6055 applies to providers of minimum essential coverage (MEC), such as health insurance issuers and employers with self-insured health plans. These entities use Forms 1094-B and 1095-B to report information about the coverage they provided during the previous year.

Section 6056 Reporting

Section 6056 applies to ALEs—generally, those employers with 50 or more full-time employees, including full-time equivalents, in the previous year. ALEs use Forms 1094-C and 1095-C to report information relating to the health coverage that they offer (or do not offer) to their full-time employees.

Combined Reporting

Employers reporting under both Sections 6055 and 6056—specifically, ALEs with self-insured plans—use a combined reporting method by filing Forms 1094-C and 1095-C.

Reporting Deadlines by Employer Type

*Alternative: Reporting entities may automatically furnish statements directly to individuals by March 2, 2026, instead of posting a website notice. Website notices must be retained until October 15, 2026. Requests must be fulfilled by the later of January 31, 2026, or 30 days after the request date.

Filing Extensions

Employers may receive an automatic 30-day extension to file with the IRS by completing and filing Form 8809 by the due date of the return. Additional extensions of time to file may also be available under certain hardship conditions.

Electronic Filing Requirements

Filing Threshold: Employers that file at least 10 returns during the calendar year must file electronically.

Key Points:

• The 10-or-more requirement applies in the aggregate to certain information returns (Forms W-2, 1099, 1094, 1095, etc.)

• Electronic filing is done using the ACA Information Returns (AIR) Program

• The electronic filing requirement does not apply to employers that request and receive a hardship waiver

• When filing electronically, follow the formatting in the 'XML Schemas' and 'Business Rules' published on IRS.gov rather than paper return formatting

Penalties for Non-Compliance

A reporting entity that fails to comply with ACA reporting requirements may be subject to penalties under Code Section 6721 (failure to file correct information returns) and Code Section 6722 (failure to furnish correct payee statements).

However, penalties may be waived if the failure is due to reasonable cause and not willful neglect. Penalties may also be reduced if the reporting entity corrects the failure within a certain period.

2026 Penalty Amounts (for 2025 Returns)

*Small employers are defined as those with average annual gross receipts of up to $5 million for the three most recent taxable years.

How Cottingham & Butler Can Help

Navigating ACA reporting requirements can be complex and time-consuming. Cottingham & Butler has the below support to ensure your organization remains compliant while minimizing administrative burden.

Our ACA Reporting Services Include:

• Compliance Assessment: We evaluate your current reporting status and identify your specific obligations under Sections 6055 and 6056

• Penalty Risk Mitigation: Proactive review and error-checking to help avoid costly penalties

• ESRP 226J Penalty Appeal: In the event the IRS issues a penalty, our team of ACA experts can assist in drafting a response to appeal the penalty

• Ongoing Compliance Guidance: Year-round support to help you stay ahead of regulatory changes and maintain compliant practices

• Form Preparation & Electronic Filing (Additional Cost): Professional preparation of Forms 1094 and 1095 with electronic submission through the IRS AIR Program

Contact your Cottingham & Butler account team to discuss how we can support your ACA reporting needs for 2026 and beyond.

This document is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice. Information is current as of January 2026.