IRS ACA Compliance Reporting Updates
What is ACA Compliance?
The Affordable Care Act (ACA) requires applicable large employers to offer affordable health insurance that provides minimum essential coverage to their full-time employees and to file the necessary reporting forms by the required deadlines.
2026 ACA Compliance Changes & Penalties
What is the compliance threshold?
The ACA requires large employers, those with 50 or more full-time equivalent (FTE) employees, to offer affordable, minimum value coverage to “substantially all” full-time employees. For 2026, “substantially all” remains defined as at least 95% of full-time employees.
Failure to identify full-time employees and offering coverage or contributing less than the ACA affordability standards may subject your company to penalties.
While an employer may intentionally or unintentionally exclude up to 5% of its employees based on this 95% rule, the employer’s actions cannot be done in a discriminatory fashion.
What are the penalties?
Penalty A: Failure to offer coverage to 95% of full-time employees
Penalty B: Failure to provide affordable, minimum value coverage
What are the deadlines for ACA Reporting?
February 28, 2026 – Deadline for filing 1094-C and 1095-C forms if filing by paper.
March 2, 2026 – Distribute 1095-C forms to employees by this date.
March 31, 2026 – E-File Deadline for 1094-C & 1095-C forms.
Special filing requirements may apply for California.
What determines affordability in 2026?
Affordability is based on the percentage of household income an employee must contribute toward coverage costs. This percentage is adjusted annually by the IRS. For 2026, the affordability threshold is 9.96% of household income.
How Ameriflex can help:
Ameriflex can mitigate the risk by mapping out and executing compliance requirements for you.
Read more about compliance in our Compliance Basics article and our Compliance Services page.