ACA Forms 1094 and 1095: 2026 Filing-Year Guide
Separate ALE status from plan funding, then verify the 2026 deadlines for reporting 2025 coverage and furnishing statements.
2 min read By Dustin Neider
Key Takeaways
- ALE status and funding type jointly determine the reporting route.
- 2025 coverage reported in 2026 is different from 2026 coverage reported in 2027.
- 2026 C-form deadlines were March 2 for standard furnishing/permitted paper filing and March 31 for electronic filing.
- Alternative furnishing does not remove IRS filing or timely request-response obligations.
ACA Forms 1094 and 1095 report health coverage and employer offers, but the correct version depends on both ALE status and plan funding. This guide addresses 2025 coverage reported in 2026, not 2026 coverage reported in 2027. ALE members generally file C forms; a non-ALE sponsoring self-insured coverage generally uses B forms.
Which forms does your organization file?
| Employer | General reporting route |
|---|---|
| ALE, fully insured | Employer files 1094-C and 1095-C for offers; insurer reports enrollment separately. |
| ALE, self-insured | Employer files C forms and uses 1095-C Part III for enrolled employees and family members. |
| Non-ALE, self-insured | Employer generally files 1094-B and 1095-B for enrollment. |
| Non-ALE, fully insured | Insurer generally handles federal enrollment reporting; employer generally has no C-form obligation. |
See the IRS C-form instructions and IRS B-form instructions, including special rules for nonemployees. An entity with fewer than 50 employees can still be an ALE member under controlled-group aggregation.
What deadlines applied in the 2026 filing year?
The 2025 IRS instructions for C forms give the following dates for 2025 coverage, absent applicable relief or extensions:
| Task | 2026 date |
|---|---|
| Furnish Form 1095-C under the standard method | March 2, 2026 |
| File C forms on paper, if permitted | March 2, 2026 |
| File C forms electronically | March 31, 2026 |
The electronic-filing threshold is generally 10 information returns in aggregate across covered return types, not 10 ACA forms alone. Use the IRS AIR system or a qualified filing provider. These dates are historical filing-year dates; do not reuse them as the calendar for 2026 coverage.
Can an employer furnish statements on request?
The IRS alternative furnishing instructions permit a clear, conspicuous, accessible website notice instead of automatically mailing every 1095-C, provided all requirements are met. For the 2026 filing year, the notice had to be posted by March 2, 2026 and retained through October 15, 2026; requests require timely fulfillment, generally within 30 days. The instructions state the later-of-January-31-or-30-days-after-request rule. This alternative does not eliminate IRS filing, and electronic delivery still requires affirmative consent. Do not describe it as simply stopping all statements.
How should errors be corrected?
Reconcile names, tax identification numbers, monthly offers, employee-required contributions, safe-harbor codes and enrollment months before filing. Follow the IRS correction instructions for the specific form and error; preserve acceptance and correction records. Filing a form does not itself establish compliance with the coverage-offer and affordability rules. Coordinate measurement-period records with payroll and HR compliance and benefits administration support.
General information for employers, not legal, tax, or medical advice; plan documents and current rules control.
To coordinate your benefits plan with these requirements, request a group health insurance quote.
Frequently Asked Questions
Does a fully insured ALE still file Form 1095-C?
Generally yes. The employer reports offers using C forms even when the insurer separately reports enrollment.
Does the alternative furnishing method eliminate IRS filing?
No. It changes how individual statements can be furnished if notice and request-response conditions are satisfied; IRS filing remains required.
Is the electronic filing threshold based only on ACA forms?
No. The general 10-return threshold aggregates covered information return types, so other returns can trigger electronic filing even with fewer than 10 ACA forms.
About the author
Dustin Neider — President of PCI Solutions, insurance broker and ACA specialist with 14+ years of experience in health insurance.
