ACA Filing Deadlines

Ticking clock counting down time for ACA reporting deadlines

Affordable Care Act Filing Deadlines

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Applicable Large Employers
While the IRS showed some leniency in 2016, starting in 2017 the IRS is adhering to strict filing deadlines for ACA reporting.

Applicable large employers (50+ Full-time employees, including Full Time Equivalents) must issue a Form 1095-C to each full-time employee, regardless of whether the employee is enrolled in an employer-sponsored health plan.  ALEs need not issue 1095Cs to full-timers who are in the health coverage waiting period.

For the IRS, 1095-C forms are submitted along with a single 1094-C transmittal form.  The transmittal serves as a summary page for the 1095-Cs.  The IRS gets one 1095-C form for each employee who was a full-time employee any month of the calendar year.  Part III of the 1095-C is only completed by self-insured ALEs.  In all other cases, Part III is left blank and the insurance company will report the coverage information on Forms 1094-B and 1095-B.

FORM 1095-C

  • Issued to employees: Tuesday, January 31, 2017 (emailed or postmarked by Jan. 31st)

FORMS 1094-C and 1095-C

  • To IRS if filing on paper: Tuesday, February 28, 2017
  • To IRS Electronically: Friday, March 31, 2017

Failure to provide individual 1095-Cs to all full time employees–and file timely or correct forms 1094-C/1095-C—can incur a penalty of up to $260 per form, for each late or incorrect 1094-C/1095-C, with a maximum annual penalty of $3,178,500.  In the event that a failure to file is due to intentional disregard, the penalty is $500 per incorrect form, and no yearly cap applies.  [Penalties are indexed yearly for inflation.]

Companies may request a 30-day extension using Form 8809.  Also, an employer filing 250 or more information returns during the calendar year must file these returns electronically.

FORM 1095-B for “Self-Insured” Companies
“Self-Insured” means that employers pay out-of-pocket for claims instead of paying a fixed premium to an insurance carrier.  Usually, insurance companies are responsible for filing forms 1095-B and 1094-B.  However, self-insured companies with fewer than 50 FT/FTEs also use 1094-B/1095-Bs. Self-insured ALEs can use section 3 of Form 1095-C/1094-C instead of filing forms 1095-B/1094-B. Self-insured ALEs must issue a 1095-C to each FT employee, as well as enrolled part-time employees, and retirees who also receive coverage.

Passport Software does not offer legal advice, please consult your accountant for tax preparation.
Learn more: IRS reporting regulations


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