ACA Reporting Requirements 2025

Affordable Care Act (ACA) compliance is complex, sure. But like the other pieces of your regulatory strategy, effectively managing it doesn’t need to be intimidating.

Even so, it’s crucial to stay on top of new expectations and guidance as ACA reporting requirements continue to evolve. For example, on Dec. 23, 2024, the president signed two bills — the Paperwork Burden Reduction Act and the Employer Reporting Improvement Act — aimed at:

• streamlining ACA reporting requirements overall
• standardizing electronic distribution of certain forms
• allowing employers more time to respond to certain requests

However, even as the acts simplify certain aspects of ACA compliance, your organization may still have an obligation to satisfy upcoming deadlines and ensure the accuracy of what you submit.

And we’ll help! By covering important deadlines, specific reporting requirements and potential fines and penalties, we’ll give you a foundation to help ace ACA compliance in 2025.

2025 ACA reporting deadlines

With ACA reporting deadlines just around the corner, don’t lose sight of these important dates:

• Feb. 28: The deadline for filing paper Forms 1094-C and 1095-C with the IRS. In 2018, the IRS extended this deadline from its original due date of Jan. 31.
• March 31: The deadline for filing electronic forms 1094-C and 1095-C with the IRS. The IRS also extended this deadline from Feb. 28 in 2018.

Keep in mind that all employers filing more than 10 total forms — such as W-2s and 1099s — must file electronically.

To simplify this process, consider investing in an automated ACA compliance tool. The right software helps ease the stress of deadlines like these while also streamlining relevant state, federal and year-end filings. In turn, HR can confidently take a step back and oversee ACA compliance, not meticulously manage it.

Who is required to file ACA reports?

ACA reporting requirements cover applicable large employers (ALEs). According to the IRS, ALEs are any employer who has at least 50 full-time employees (FTEs), or full-time equivalent employees, on average during the previous year. (This may exclude certain employees with health care coverage through the military.)

ALEs aren’t legally required to offer health insurance to part-time workers and employees who have worked for the business for under three months. Certain employers may hold these benefits for new hires as part of a 90-day review process. Others may initiate such coverage immediately as the result of pre-hire negotiations or company policy. As long as your procedure is compliant, the best path will be determined by your company’s unique needs.

Not sure if your organization is covered or you employ enough FTEs? Consult the ACA resources from the IRS and seek advice from a licensed legal professional.

If your business isn’t an ALE, you may not need to file forms 1094-C or 1095-C with the IRS. Of course, you still have the option to offer health insurance to your employees. Unlike certain unconventional benefits, most candidates expect health care coverage as a basic and expected part of their compensation.

ACA reporting penalties

Like most compliance requirements, failing to accurately file ACA data on time without a reasonable cause could subject your organization to costly penalties. These consequences work similar to other late forms, like Form W-2, in that they increase based on the time lost.

In 2025, employers that miss an ACA reporting deadline may receive fines for each required document of:

• $60 for up to 30 days late, for a maximum penalty of $683,000 per year (or $239,000 for qualified small businesses*)
• $130 for being 31 days late through Aug. 1, for a maximum penalty of $2,049,000 per year (or $683,000 for qualified small businesses)
• $330 after Aug. 1 or for not filing at all, for a maximum penalty of $4,098,500 per year (or $1,366,000 for qualified small businesses)
• $660 for intentionally disregarding a filing date, with no maximum penalty for ALEs or qualified small businesses

*The IRS defines qualified small businesses as a corporation or partnership with gross receipts of $5 million or less for the three most recent tax years (or for the period an organization has existed, if it’s shorter) ending before the calendar year when returns were due.

How do I simplify ACA reporting requirements?

ACA compliance is undeniably important. Ideally, you should make this process easier on yourself by investing in the right tools. Look into an automated ACA reporting tool that helps you:

• stay on top of important deadlines with proactive notifications
• create regular monthly reports that alert you to any ACA status changes
• test premium affordability to ensure your health care offers are within ACA compliance
• electronically file any relevant form without guesswork

Ultimately, your organization’s ability to comply defines its legitimacy as a business. Don’t leave it up to chance; take the appropriate steps to prepare and pivot your regulatory strategy as soon as possible. After all, with the right approach and tools at your disposal, you’ll have what it takes to comply with confidence.

FAQ

What is an applicable large employer (ALE)?

An ALE is an employer who on average employs 50 or more full-time workers — or the equivalent of full-time workers — during the previous year. However, employers who don’t qualify as an ALE may still offer health care coverage to their employees; they just may not have a legal obligation to do so.

What is needed for ACA reporting?

ALEs covered by the ACA must complete and file Forms 1094-C and 1095-C with the IRS. Additionally, these employers must file all applicable forms through mail by Feb. 28 or electronically by March 31.

What are the ACA minimum requirements?

The ACA applies to employers with at least 50 full-time or full-time equivalent workers. Employers must also file any relevant IRS forms completely and accurately by the appropriate deadlines or they could be subject to escalating penalties for each form in question.