The ACA deadline to furnish 1095-Cs to employees is March 2, 2026, and March 31st is the deadline to electronically file Forms 1094-C and 1095-C.

The paper filing deadline (only for employers with <10 aggregated returns) is March 2, 2026, due to Feb 28, 2026, being a Saturday.

The deadline to post the ACA Notice of Availability on a company website is March 2, 2026. This notice informs employees that they may request a copy of Form 1095-C or 1095-B, rather than receiving one automatically by mail.

However, if you have employees in California, New Jersey, or Rhode Island, you must still furnish physical forms by their specific state deadlines (e.g., California’s furnishing deadline is January 31, 2026).

Data Validation

After furnishing forms to employees, it’s important to validate ACA-related data before filing with the IRS, as errors can trigger a penalty assessment notice.

The IRS cross-references Form 1095-C data with W-2 data by using automated matching systems. Offers of health coverage (1095-C) must align with W-2 data:

• The Employee Identification Number, Social Security Number, and name on Form 1095-C must match the W-2, verifying employee status as a full-time employee.
• Coverage reported on the W-2 must match the affordability codes in Part II of the 1095-C.
• The IRS uses the 1094-C Transmittal form to verify the total number of employees, full-time employees, and total 1095-C forms submitted against the employer’s reported payroll data.
• The IRS compares the codes on Line 14 and 16 of the 1095-C (indicating if coverage was offered and accepted) with the W-2, as well as with individual 1095-A/B forms to determine if an employee received a Premium Tax Credit (PTC). If an employee received a PTC while the employer indicated in 1095-C that affordable coverage was offered, the IRS may trigger a penalty review.

If you need time to make corrections, you can file Form 8809 (Application for Extension of Time to File Information Returns). This provides an automatic 30-day extension to file with the IRS and must be submitted by March 31^st.

Accuracy

Once W-2s have been issued, you can double check the accuracy of your affordability safe harbor calculations. With the W-2 Safe Harbor, confirm the employee’s required contribution did not exceed the allowable percentage of actual wages.

The time to correct coding is before submission, and it’s also important to abide by state reporting requirements. Adhering to state compliance regulations, as well as federal requirements, is crucial for preventing penalties.

Validating your data before filing reduces the likelihood of penalties and time-consuming amendments.

Passport Software

Effective ACA compliance management requires year-round data management. Our affordable, IRS-certified ACA software solution streamlines data tracking throughout the year. We are also IRS-certified for proxy-submission on behalf of our ACA software customers.

The ACA Full Service option is the most convenient choice for clients who prefer to outsource ACA reporting to our experts. Just submit a simple spreadsheet containing employee information, and we will handle everything else, including proxy submission.

Passport Software provides single-year solutions and multi-year filing customized to meet the requirements of any Applicable Large Employer. We manage all aspects for you throughout the year, from handling ACA-related employee data to electronic filing.

At Passport Software, our experienced support team is available to guide you through the process and alleviate the challenges associated with managing Affordable Care Act compliance.

Outstanding customer support and consultation are key components of our ACA software and services. Regardless of whether you are using our ACA compliance software or Full Service option, we offer exceptional support.

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.