ACA Reporting Update – Electronic Filing Required by March 31, 2026

We want to make sure you’re aware of an important ACA reporting update that could impact your business.

What’s Changing?

The IRS has lowered the threshold for mandatory electronic ACA filing.

In the past, employers only had to file electronically if they submitted 250 or more forms. Now, if you file 10 or more total information returns in a year (including Forms 1095, W-2s, 1099s, etc.), you are required to file your ACA returns electronically.

For most small businesses, this means electronic filing is now required.

Key Deadlines

March 2, 2026
You must either:

• Post a notice on your website letting employees know they can request a copy of their Form 1095-B or 1095-C, or
• Provide the forms directly to employees by this date.

March 31, 2026
Deadline to electronically file your 2025 ACA returns with the IRS.

What This Means for You

If your business is subject to ACA reporting rules and you have not requested:

• An extension, or
• A waiver from electronic filing

you’ll need to ensure your filing is completed electronically by March 31, 2026.

Many employers use a third-party vendor or payroll provider to handle this process, which is often the simplest route.

Can You Request a Waiver?

In limited hardship situations, you may request a waiver from electronic filing. The first waiver request is typically granted, but documentation may be required in certain cases. Waivers must be requested before the filing deadline.

You may also request a 30-day filing extension by submitting IRS Form 8809.

We’re Here to Help

ACA reporting can feel technical and overwhelming — especially with rule changes like this. As always, Zinn Insurance is here to help guide you through your options and connect you with the right resources to stay compliant and avoid penalties.

If you have questions about how this applies to your business, please reach out. We’re happy to walk through it with you.