ACA Reporting: 2025 coverage filed and furnished in 2026

2026 ACA Reporting Deadlines and Penalty Ranges, Built for Fast Decisions

Use this page as a practical checklist for Forms 1094 and 1095 timing, who files what, and how penalty exposure typically scales when items are late or incorrect. If you want a second set of eyes, Omnia Benefit Partners can help you confirm which bucket you fall into and what to prioritize first.

Step 1: Identify your filing category

Start with two questions: Are you an Applicable Large Employer (ALE), and is your medical plan fully insured or self funded. Those answers drive whether you file the B series, the C series, or both.

Helpful shorthand
6055 coverage reporting (commonly self funded)
6056 employer offer reporting (ALEs)

Step 2: Map forms to people

Different audiences receive different forms. Employees and covered individuals may request copies when the alternative furnishing method is used, and the timing rules matter.

Requests must be handled fast
Provide the form by the later of Jan 31, 2026 or 30 days after the request date.
Track requests

Step 3: Reduce penalty risk

Penalties generally increase when issues are not corrected early. Even when mistakes happen, a documented correction process can materially lower exposure.

Best leverage point
Corrections within 30 days are treated far more favorably than later fixes.
Move early

Reporting deadlines by employer and coverage type

Calendar year 2025 coverage, filed and furnished during 2026.

Action Fully insured ALE Self or level funded ALE Self or level funded non-ALE
Electronically file 1094-C and 1095-C with the IRS
Employer offer reporting under the C series.
March 31, 2026 March 31, 2026 Not applicable
Electronically file 1094-B and 1095-B with the IRS
Coverage reporting under the B series.
Not applicable If you cover non-employees under a self or level funded plan, you can typically report their coverage using either the B series or the C series.
March 31, 2026
March 31, 2026
Provide 1095-C to full-time employees upon request
Alternative furnishing relies on a website notice plus request fulfillment timing.
Post notice by March 2, 2026
Keep posted through Oct 15, 2026
Fulfill requests by the later of Jan 31, 2026 or 30 days after request
Post notice by March 2, 2026
Keep posted through Oct 15, 2026
Fulfill requests by the later of Jan 31, 2026 or 30 days after request
Not applicable
Provide 1095-B to responsible individuals upon request
Alternative furnishing rules are similar when applicable.
Not applicable If you provide self or level funded coverage to non-employees, you may typically use either 1095-B or 1095-C to reflect coverage for those individuals.
Post notice by March 2, 2026
Keep posted through Oct 15, 2026
Fulfill requests by the later of Jan 31, 2026 or 30 days after request
Post notice by March 2, 2026
Keep posted through Oct 15, 2026
Fulfill requests by the later of Jan 31, 2026 or 30 days after request

Important practical note

  • If you decide not to use the alternative furnishing method, you can furnish Forms 1095 directly by March 2, 2026 instead of relying on the website notice approach.
  • Even when federal timing is handled, state level reporting may still apply depending on where employees and covered individuals live.

Adjusted reporting penalties (2025 returns furnished and filed in 2026)

Amounts are generally assessed per failure and may cap differently for small employers.

Penalty category Per violation Annual maximum Annual maximum for small employers
General failures
Late, missing, or incorrect returns or statements.
$340 $4,098,500 $1,366,000
Corrected within 30 days
Most favorable correction tier.
$60 $683,000 $239,000
Corrected after 30 days and before Aug 1
Still better than no correction, but higher than the 30 day window.
$130 $2,049,000 $683,000
Intentional disregard
Generally no maximum cap.
$680 No limit No limit

When penalties may be reduced or waived

  • Relief can be available when a failure is due to reasonable cause rather than willful neglect, especially when you can show you acted promptly to correct.
  • Keeping a clean audit trail helps: documented vendor communications, correction logs, and proof of website notice posting if you use the alternative furnishing method.

What to do next

A simple workflow you can follow in under an hour.

1) Confirm ALE status

If the prior year full-time equivalents put you at 50 or more, treat yourself as an ALE and prioritize the C series deliverables.

2) Confirm funding type

Fully insured vs self funded changes who handles coverage reporting. If you are self or level funded, 6055 coverage reporting comes into play.

3) Decide how you will furnish

Either deliver statements directly by March 2, 2026, or use the alternative furnishing method and be ready to fulfill requests on time.

Optional: Create a small compliance tracker

  • One row per deliverable: IRS filing, website notice posting, request log, corrections.
  • Assign an owner and a date for each item, then add a “proof” column for screenshots, confirmations, or vendor receipts.

FAQs people ask before they file

Click to expand. Built to be copy friendly for internal teams.

ALEs generally focus on the 1094-C and 1095-C filings because those documents support employer offer reporting. If the ALE is also self or level funded, coverage reporting responsibilities can also apply depending on who is being covered.

Instead of automatically mailing Forms 1095 to everyone, you post a compliant website notice by March 2, 2026 and keep it up through Oct 15, 2026. Then you provide the form to anyone who asks, within the required request window.

Requests must typically be satisfied by the later of January 31, 2026 or 30 days after the request is received. Practically, a simple request log with dates and fulfillment proof protects you.

Correct early and document everything. The “corrected within 30 days” tier is dramatically lower than general failures. If you miss the 30 day window, correcting before Aug 1 is still better than leaving the issue unresolved.

Source: 2026 ACA Reporting Deadlines and Penalties Cheat Sheet :contentReference[oaicite:1]{index=1} General information only. Not legal or tax advice. Confirm specifics with your tax advisor or counsel.