Q: As the 2025 calendar year comes to an end, what are the requirements for Affordable Care Act (ACA) reporting that are due in 2026?
A: The ACA requires employers to comply with Section 6055 and 6056 reporting. Employers must comply with 6056 filing requirements if the employer is an Applicable Large Employer (ALE). All employers who offer a self-insured medical plan which includes level funded Individual Coverage Health Reimbursement Account are required to comply with 6055 reporting requirement.
Applicable Large Employer (ALE)
Employers must comply with ACA Section 6056 filing requirements if they are considered an Applicable Large Employer (ALE).
An ALE is defined as an employer with 50 or more full-time equivalent employees in the prior calendar year.
ALEs are required to report to the IRS on the offer of medical coverage made to full-time employees and their dependents. Under the ACA, a full-time employee is one who averages 30 or more hours per week based on the ACA measurement method.
The offer of coverage must:
- Provide Minimum Essential Coverage (MEC)
- Provide Minimum Value (MV)
- Be affordable for the lowest-cost self-only plan offered
For the 2025 reporting year, coverage is considered affordable if the employee’s required contribution for the lowest-cost self-only plan does not exceed the applicable affordability percentage. For plan years beginning in 2024 and ending in 2025, the affordability percentage is 8.39%. The affordability percentage for plan years beginning on or after January 1, 2025 is 9.02%. Looking ahead, the affordability percentage for plan years beginning on or after January 1, 2026, will be 9.96%.
All ALE’s are required to file forms 1094-C and 1095-C to fulfill the 6056 reporting. These forms fulfill the employer’s 6056 reporting as well as the 6055 reporting requirement if appliable. If ALE offers a self-insured plan, level-funded plan or Individual Coverage Health Reimbursement Account (ICHRA), they must complete Part III of form 1095-C to fulfill the 6055-reporting requirement.
The forms did not change from last year. The 2025 Instructions for Forms 1094-C and 1095-C includes the current codes to use and filing requirements.
Small Employer (Non ALE)
Small employers (those not considered ALE) that offer employees a self-funded health plan, level funded plan, or Individual Coverage Health Reimbursement Account (ICHRA) are required to fulfill the Section 6055 reporting.
These employers must file which report to the IRS what employees and dependents were enrolled in coverage that providing Minimum Essential Coverage (MEC) and Minimum Essential Value (MEV).
These employers must file Forms 1094-B and 1095-B. The 2025 Instructions for Forms 1094-B and 1095-B includes detailed instructions and filing requirements.
Filing Requirements for 6055 and 6056 Reporting
- Electronic Filing Threshold – Employers must file electronically if they have 10 or more information returns. Reporting entities must aggregate most information returns, such as Forms W-2, 1099, 1095-C, and 1095-B, to determine if the 10 returns threshold for electronic filing is met.
- Employer Copy Distribution – Employers no longer have to automatically send Form 1095-C to individuals. Employers can now post a notice on their website informing individuals that they may request a copy of the statement. The requirement to provide the statement is met as long as the notice is:
- Clear, conspicuous, and easily accessible to all responsible individuals.
- Timely posted, which for tax year 2025 is by March 2, 2026, and retained until October 15th of the filing year; and
- Furnished within 30 days of receiving the individual’s request.
- For additional guidance, see IRS Notice 2025-15 if you are filing electronically.
- Filing Deadlines with the IRS – Paper forms are due by March 2, 2026 and electronic filings are due March 31, 2026.
Additional Information: ACA Violations and Excise Taxes
Failure to file required forms or provide accurate statements may result in ACA excise taxes and penalties under the Internal Revenue Code. Employers should review their reporting procedures to ensure compliance and avoid potential penalties.
To learn more about how Liberty Insurance Agency can help protect your business and employees, contact us at 412-571-5700 or visit our website at libertyins.com.
Employer Resources
