Employers subject to the Affordable Care Act (ACA) reporting requirements under Sections 6055 and 6056 must adhere to specific filing deadlines to ensure compliance. Below is an overview of the latest deadlines, including any extensions granted by the IRS, along with the reporting obligations for applicable employers.
Key Filing Deadlines for 2025 Reporting (Tax Year 2024)
- Form 1095-C or 1095-B Distribution to Employees
- Original Deadline: January 31, 2025.
- Extended Deadline: March 2, 2025 (automatic extension granted by the IRS for furnishing these forms to employees).
- Filing with the IRS (Paper Filing)
- Deadline: February 28, 2025.
- Filing with the IRS (Electronic Filing)
- Deadline: April 1, 2025 (required for employers filing 10 or more forms).
Overview of Sections 6055 and 6056
Section 6055 Reporting
- Applies to: Insurance providers and self-insured employers.
- Purpose: To report individuals covered by minimum essential coverage (MEC) to verify compliance with the individual mandate.
- Form Used: Form 1095-B.
Section 6056 Reporting
- Applies to: Applicable large employers (ALEs) with 50 or more full-time equivalent employees.
- Purpose: To report whether the employer offered affordable health coverage providing minimum value to full-time employees (and their dependents).
- Form Used: Form 1095-C.
Penalties for Non-Compliance
Failure to comply with ACA reporting requirements can result in penalties:
- Failure to furnish forms to employees: $310 per form, up to a maximum of $4,532,500 per calendar year.
- Failure to file with the IRS: Additional penalties apply at the same rates as above.
Employers should also be aware that late filings or incomplete information may incur penalties, though the IRS may grant relief for “reasonable cause.”
Steps for Employers to Stay Compliant
- Verify ALE Status: Confirm whether your organization meets the ALE threshold for the applicable tax year.
- Collect Data Early: Ensure accurate tracking of employee hours, coverage offers, and dependent enrollments.
- Leverage Technology: Use ACA compliance software to simplify data aggregation and ensure timely submissions.
- Engage Experts: Work with benefits advisors or ACA consultants to manage complex reporting requirements.
Key Considerations for Extensions
The IRS has granted automatic extensions for providing Forms 1095-C and 1095-B to employees. However, no extensions are available for filing forms with the IRS unless formally requested using Form 8809. Employers are encouraged to file as early as possible to avoid last-minute errors or delays.
By staying informed of ACA reporting deadlines and leveraging the right resources, employers can remain compliant and avoid costly penalties.