Every year, employers across the United States face a critical compliance question: when is the ACA filing deadline to submit health coverage information returns to the IRS? This question matters enormously because missing these deadlines triggers significant financial penalties that can quickly add up to thousands or even millions of dollars for larger employers. The Affordable Care Act requires certain employers and health coverage providers to report detailed information about the health insurance they offer or provide, and the IRS enforces strict timelines for these submissions.
The ACA filing deadline represents more than just an administrative date on the calendar. It marks the point after which employers face escalating penalties for each day, week, and month of delay. For tax year 2025, the primary deadline for electronic filing of ACA forms with the IRS is March 31, 2026. However, understanding the complete picture requires knowing about multiple deadlines, extension options, state-level requirements, and the consequences of non-compliance.
This comprehensive guide covers everything you need to know about when ACA forms are due to the IRS. Whether you are an Applicable Large Employer (ALE) required to file Forms 1094-C and 1095-C, a health insurance provider filing Forms 1094-B and 1095-B, or a third-party administrator handling ACA reporting for clients, understanding these deadlines is essential for compliance. We will explain the exact dates, walk through the extension process, detail the penalties for late filing, and help you develop a timeline for successful ACA reporting.
The information in this guide reflects current IRS requirements for tax year 2025 (filed in 2026). Key topics include:
For tax year 2025, the ACA filing deadline for submitting Forms 1094-B, 1095-B, 1094-C, and 1095-C to the IRS electronically is March 31, 2026. This date represents the final day by which employers and coverage providers must transmit their ACA information returns to the IRS through the Affordable Care Act Information Return (AIR) system. Electronic filing is mandatory for any filer submitting 10 or more information returns of any type during the calendar year.
The March 31 ACA filing deadline applies to all electronic filers, which includes virtually all Applicable Large Employers and most insurance providers. Given that ALEs by definition have at least 50 full-time employees (or full-time equivalents), they will almost always exceed the 10-return threshold that mandates electronic filing. Similarly, insurance companies and self-insured employers providing coverage typically file far more than 10 returns.
Important details about the March 31 deadline:
The ACA filing deadline has remained consistent at March 31 for electronic filers since the IRS finalized its ACA reporting requirements. Unlike some other deadlines that have been extended or modified over the years, this date has proven stable, allowing employers to plan their compliance calendars accordingly.
While electronic filing is required for most ACA filers, a paper filing option technically exists for those submitting fewer than 10 information returns total during the year. For these rare cases, the ACA filing deadline for paper submissions is February 28, 2026 for tax year 2025 returns. This earlier deadline reflects the additional processing time the IRS needs for paper documents.
Characteristics of paper filing for ACA forms:
In practice, very few ACA filers use the paper option. Any employer with 50 or more full-time employees (the ALE threshold) will have at least 50 Forms 1095-C to file, far exceeding the 10-return electronic filing mandate. Similarly, insurance providers covering multiple individuals almost always file electronically. The paper filing deadline is primarily relevant for very small self-insured employers or certain unusual circumstances.
The IRS strongly encourages electronic filing for all ACA information returns, and the 10-return threshold effectively mandates it for most filers. Electronic filing through the AIR system offers significant advantages when meeting the ACA filing deadline:
| Advantage | Electronic Filing | Paper Filing |
|---|---|---|
| Deadline | March 31 | February 28 |
| Confirmation | Immediate acknowledgment | No confirmation unless using certified mail |
| Error Detection | Automated validation during submission | Errors discovered during manual processing |
| Corrections | Easy electronic resubmission | Requires new paper forms |
| Record Keeping | Digital records automatically maintained | Must maintain paper copies |
| Volume Handling | Unlimited forms in single transmission | Physical mailing constraints |
For most employers, electronic filing is not optional—it is required. Using an authorized e-file provider like BoomTax simplifies the process by handling the technical requirements of AIR system transmission, ensuring your forms reach the IRS well before the ACA filing deadline.
While the ACA filing deadline for IRS submission is March 31, employers and coverage providers face an earlier deadline for delivering copies to employees and covered individuals. For tax year 2025, Forms 1095-C and 1095-B must be furnished to recipients by March 3, 2026. This deadline has been extended from the original January 31 statutory date through regulatory relief that the IRS has consistently provided.
The March 3 furnishing deadline gives employers additional time beyond the original statutory requirement. The extension recognizes the complexity of ACA reporting and the challenges employers face in gathering accurate data for all full-time employees. However, this deadline remains firm—employers must ensure recipients have their forms in time to use the information for personal tax preparation if needed.
Key points about the employee furnishing deadline:
The furnishing deadline is separate from the ACA filing deadline for IRS submission. Employers must meet both deadlines: forms to recipients by March 3, and forms to the IRS by March 31. Missing either deadline triggers distinct penalty provisions.
Employers may furnish Forms 1095-C and 1095-B electronically rather than by mail, but only if they obtain proper consent from each recipient. The IRS has specific requirements for electronic delivery that must be followed to satisfy the furnishing obligation by the ACA filing deadline:
Consent requirements for electronic delivery:
Many employers use a combination of electronic and mail delivery. Employees who have consented receive their forms through a secure online portal or email link, while those who have not consented receive traditional mailed copies. This hybrid approach can reduce costs while meeting all compliance requirements.
Missing the recipient furnishing deadline results in penalties separate from those for missing the IRS ACA filing deadline. The IRS treats the obligation to furnish forms to recipients as distinct from the obligation to file with the IRS. Penalties for late furnishing follow the same structure as late filing penalties:
| Timing of Furnishing | Penalty per Form | Maximum Penalty (Large Filers) |
|---|---|---|
| Within 30 days of deadline | $60 | $630,500 |
| More than 30 days late but by August 1 | $130 | $1,891,500 |
| After August 1 or not at all | $330 | $3,783,000 |
| Intentional disregard | $660 (minimum) | No maximum |
These furnishing penalties can apply in addition to filing penalties, potentially doubling the financial impact of ACA compliance failures. An employer who both fails to furnish forms to employees and fails to file with the IRS could face penalties on both fronts for each affected form.
Employers who cannot meet the March 31 ACA filing deadline may request an automatic 30-day extension by filing Form 8809, Application for Extension of Time to File Information Returns. This extension request must be submitted before the original deadline and provides additional time to file Forms 1094-B, 1095-B, 1094-C, and 1095-C with the IRS.
Key points about the automatic extension:
The extension is "automatic" in that it does not require IRS approval or a specific justification. As long as Form 8809 is properly completed and submitted before the ACA filing deadline, the extension is granted. However, this extension only applies to the IRS filing deadline—it does not extend the deadline for furnishing forms to employees.
In certain circumstances, filers may request an additional 30-day extension beyond the initial automatic extension, for a total of 60 days of additional time. This second extension is not automatic and requires demonstrating extraordinary circumstances or undue hardship. The IRS grants these additional extensions sparingly.
Circumstances that may support an additional extension request:
To request the additional extension, filers must submit another Form 8809 before the extended deadline expires and must include a written explanation of the circumstances requiring additional time. The IRS will notify the filer whether the additional extension is approved or denied.
Extensions for the recipient furnishing deadline work differently than extensions for the IRS ACA filing deadline. There is no automatic extension available for furnishing Forms 1095-C or 1095-B to employees and covered individuals. However, the IRS may grant extensions for furnishing in hardship situations.
To request an extension for furnishing, employers must send a letter to the IRS that includes:
These extension requests are evaluated on a case-by-case basis. Employers should not assume an extension will be granted and should make every effort to furnish forms by the deadline. Even if an extension is requested, begin the furnishing process immediately to minimize any potential delay.
Several states have implemented their own individual health insurance mandates and require separate state-level ACA reporting. These state requirements exist alongside the federal ACA filing deadline and impose additional deadlines and filing obligations. Missing state deadlines can result in state-level penalties independent of any federal consequences.
States currently requiring separate ACA information reporting include:
Each state sets its own deadlines, which may differ from the federal ACA filing deadline. Some states align their deadlines with federal dates for simplicity, while others have established independent timelines. Employers with employees in multiple states may need to track several different deadlines.
| State | Forms Required | Filing Deadline (TY2025) | Furnishing Deadline |
|---|---|---|---|
| California | 1095-B, 1095-C | March 31, 2026 | March 3, 2026 |
| New Jersey | 1095-B, 1095-C | March 31, 2026 | March 3, 2026 |
| Rhode Island | 1095-B, 1095-C | March 31, 2026 | March 3, 2026 |
| District of Columbia | 1095-B, 1095-C | April 30, 2026 | March 3, 2026 |
| Massachusetts | MA 1099-HC | March 31, 2026 | January 31, 2026 |
Note that state deadlines and requirements can change. Employers should verify current requirements with each state agency or use a compliance service that stays current with state-level changes. The ACA filing deadline at the federal level does not automatically satisfy state obligations—separate filings are required.
Employers with employees in multiple states with individual mandates face the challenge of tracking and meeting several deadlines simultaneously. Best practices for managing these requirements alongside the federal ACA filing deadline include:
Services like BoomTax support both federal and state ACA filing, allowing employers to submit all required forms from a single platform rather than managing separate submission processes for each jurisdiction.
The IRS imposes substantial penalties for failing to file ACA information returns by the ACA filing deadline or for filing returns with incorrect or incomplete information. These penalties are assessed per form and increase based on how late the filing occurs. The penalty structure for tax year 2025 returns (filed in 2026) is:
Late filing penalties (per form):
| Filing Timing | Penalty Amount | Example: 500 Forms |
|---|---|---|
| Filed within 30 days of deadline | $60 per form | $30,000 |
| Filed more than 30 days late but by August 1 | $130 per form | $65,000 |
| Filed after August 1 or not filed | $330 per form | $165,000 |
| Intentional disregard of requirements | $660 per form (minimum) | $330,000+ |
These penalties apply separately for each failure—failure to file with the IRS and failure to furnish to recipients can both result in penalties for the same form. An employer who misses both deadlines could face double the penalty amounts shown above.
The IRS does cap total annual penalties for non-intentional failures, providing some limit on exposure for filers who miss the ACA filing deadline. However, these caps are quite high and provide little comfort for large employers:
| Timing of Correction | Maximum Penalty (Large Filers) | Maximum Penalty (Small Filers) |
|---|---|---|
| Filed within 30 days | $630,500 | $220,500 |
| Filed by August 1 | $1,891,500 | $630,500 |
| Filed after August 1 | $3,783,000 | $1,261,000 |
Small filers (gross receipts of $5 million or less) benefit from lower caps, but the amounts are still substantial. There is no cap for penalties assessed due to intentional disregard of the filing requirements. The IRS considers a failure to be intentional disregard if the filer knew of the requirement and chose not to comply.
Penalties may be waived if the filer can demonstrate "reasonable cause" for the failure to meet the ACA filing deadline. Reasonable cause exists when the filer exercised ordinary business care and prudence but still could not file timely. Factors the IRS considers include:
To claim reasonable cause, include a written statement explaining the circumstances with your late filing. Document all efforts made to comply and any factors that prevented timely filing. The IRS evaluates reasonable cause claims on a case-by-case basis, and there is no guarantee of penalty relief.
Successful ACA compliance begins months before the ACA filing deadline. Use the final quarter of the tax year to prepare your data and systems:
October:
November:
December:
January is critical for preparing accurate forms before the ACA filing deadline:
Early January:
Mid-January:
Late January:
These months involve executing your filing plan to meet the ACA filing deadline:
February:
Early March:
Mid-to-Late March:
Compliance doesn't end at the ACA filing deadline:
April:
Ongoing:
The ACA filing deadline for tax year 2025 is March 31, 2026 for electronic filers and February 28, 2026 for paper filers. Electronic filing is mandatory for any filer submitting 10 or more information returns during the calendar year, which includes virtually all Applicable Large Employers and insurance providers.
Applicable Large Employers must file Forms 1094-C (transmittal) and 1095-C (one per full-time employee). Insurance providers and small self-insured employers file Forms 1094-B (transmittal) and 1095-B (one per covered individual). Some employers may need to file both sets of forms. Understanding the difference between 1095-B and 1095-C is explained in our guide on the two forms.
Yes, you can request an automatic 30-day extension by filing Form 8809 before the original deadline. This extension applies only to the IRS filing deadline and does not extend the deadline for furnishing forms to employees. Additional extensions beyond 30 days may be available in extraordinary circumstances but require demonstrating hardship.
Forms 1095-C and 1095-B must be furnished to recipients by March 3, 2026 for tax year 2025. This deadline has been extended from the original January 31 statutory date. There is no automatic extension available for the furnishing deadline, though the IRS may grant extensions in hardship situations.
Penalties range from $60 per form if filed within 30 days of the deadline to $330 per form if filed after August 1 or not filed at all. Penalties for intentional disregard start at $660 per form with no maximum cap. These penalties apply separately for filing and furnishing failures, so total exposure can be double these amounts.
If you have employees in California, New Jersey, Rhode Island, District of Columbia, or Massachusetts, you may have state-level filing requirements in addition to federal ACA reporting. Each state has its own deadlines and requirements. Federal filing does not satisfy state obligations where separate state mandates exist.
You should file corrected returns as soon as you discover errors. Use the same forms (1094/1095) marked as corrected and submit them through the AIR system. There is no specific deadline for corrections, but filing promptly demonstrates good faith compliance. Services like BoomTax include unlimited corrections at no additional charge.
You are required to file if you are an Applicable Large Employer (50 or more full-time employees including full-time equivalents) or if you are an insurance provider, including self-insured employers who provide health coverage. ALE status is determined based on the prior calendar year's employment numbers.
Yes, you can furnish forms electronically if you obtain proper consent from each recipient. Consent must be affirmative and informed, and recipients must be told they can receive paper copies instead. Electronic delivery can reduce costs and ensure timely receipt when properly implemented.
If March 31 or any deadline falls on a Saturday, Sunday, or federal holiday, the deadline is extended to the next business day. For example, if March 31 falls on a Saturday, the deadline would move to Monday, April 2 (or Tuesday, April 3 if Monday is a holiday).
No, both forms have the same filing and furnishing deadlines. Form 1095-C is filed by Applicable Large Employers for full-time employees, while Form 1095-B is filed by insurance providers for covered individuals. Both are due to the IRS by March 31 (electronic) and must be furnished to recipients by March 3.
Review the notice carefully to understand which forms and what penalties are being assessed. If you have reasonable cause for the late filing, respond with a written explanation and supporting documentation. If the penalty is accurate, you can request a payment plan if needed. Consulting with a tax professional may be advisable for significant penalty assessments.
Meeting the ACA filing deadline requires careful preparation, accurate data, and reliable filing capabilities. BoomTax provides a comprehensive solution that simplifies every aspect of ACA compliance:
BoomTax offers transparent pay-per-form pricing with no subscription fees, making it cost-effective for employers of all sizes. The platform is trusted by thousands of employers, payroll providers, HR service companies, and insurance carriers nationwide for reliable, timely ACA compliance.
Ready to file your ACA forms on time? Get started with BoomTax today and eliminate the stress of approaching deadlines.
The ACA filing deadline represents a firm compliance milestone that Applicable Large Employers, insurance providers, and self-insured employers must meet each year. For tax year 2025, the key dates are clear: furnish Forms 1095-B and 1095-C to recipients by March 3, 2026, and file with the IRS electronically by March 31, 2026. Missing these deadlines triggers escalating penalties that can quickly become substantial for larger filers.
Key takeaways about the ACA filing deadline:
Success in meeting the ACA filing deadline comes from preparation, accurate data, and reliable filing tools. Build a compliance calendar that accounts for all deadlines—federal, state, and the separate recipient furnishing requirement. Use validation tools to catch errors before submission rather than discovering them through IRS rejections. And work with an authorized e-file provider like BoomTax that handles the technical requirements of AIR system transmission.
ACA compliance is an annual obligation that requires ongoing attention. Each year brings a new set of deadlines, and missing them creates financial exposure that compounds with each passing day. By understanding exactly when ACA forms are due and building a process to meet those deadlines consistently, employers can fulfill their ACA reporting requirements without the stress and penalties that come from last-minute scrambling.
BoomTax and its affiliates do not provide tax, legal, or accounting advice. This material has been prepared for informational purposes only, and is not intended to provide, and should not be relied on for, tax, legal, or accounting advice. You should consult your own tax, legal, and accounting advisors prior to engaging in any transaction.