2024 ACA Reporting Deadlines, Affordability, Threshold and Penalties

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This post is for Applicable Large Employers (ALEs) required to comply with the Affordable Care Act. We hope you find it useful.

The 2024 ACA reporting deadlines for the 2023 tax year are as follows:

– The electronic filing deadline is April 1, 2024.
– The deadline for furnishing forms 1095-C to employees is March 1, 2024.
– The paper filing deadline is February 28, 2024. ALEs with 10+ 1095-C forms must file electronically.

The threshold for electronic filing has been lowered to 10+ returns in a calendar year. This means an ALE that files 10+ returns or forms in a calendar year is required to e-file in 2024. The 10-return threshold includes: Forms 1042-S, 1094 series, 1095-B, 1095-C, 1097-BTC, 1098, 1098-C, 1098-E, 1098-Q, 1098-T, 1099 series, 3921, 3922, 5498, 8027, W-2, and W-2G.

2024 Penalties

The 2024 ACA late filing and non-compliance penalties are:

– 4980H(a) $2,970 per full-time employee, excluding the first 30 employees. 4908H(a) is levied for failure to offer minimum essential coverage to at least 95% of full-time employees and dependents.
– 4980H(b) $4,460 for each full-time employee who receives the Premium tax credit and enrolls in Marketplace coverage. 4908H(b) is levied for failure to offer coverage to qualifying employees that is affordable under IRS criteria.
– Late/incorrect filing – $310 for Forms 1094/5-C for a total of $620 per employee or $630 for willful non-compliance.
– Some states have their own requirements and issue state ACA penalties accordingly.

Affordability Threshold

The IRS has lowered the ACA affordability threshold for plans starting in 2024: At 8.39% of an employee’s household income, this is a significant decline from 2023’s 9.12% and 2022’s 9.61%. Therefore, employers will need to carry more of health plans’ costs for eligible employees or risk steep IRS penalties.

The adjusted percentage applies on a plan-year basis, so continue to use 9.12% to calculate affordability in 2024 until the new plan year begins, if it doesn’t begin at the start of the calendar year.

It’s important to keep up with changes to the ACA in order to remain compliant and avoid costly penalties for your clients. Passport Software has been helping ALEs simplify and comply since the inception of the ACA.

If you are busy with numerous responsibilities and overwhelmed with ACA compliance management, we can help. If you are doing all the work on behalf of your payroll service or paying too much for your ACA provider, Passport Software’s ACA software and services can help you simplify and comply.

Our IRS-certified ACA software simplifies filing and compliance management throughout the year to help avoid costly penalties. With ACA Full Service, we do it all for you year-round, including filing. Outsourcing can save you time, money, and allows you to turn over the entire process to an ACA expert.

To learn more about how our ACA software and services can ease the burden of compliance, call 800-969-7900. Or, contact us – we are here to help.


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