Don’t Miss these ACA Reporting Requirements for 2025
It’s hard to believe that more than a decade has passed since the Patient Protection and Affordable Care Act (ACA) was signed into law during the Obama administration. Nicknamed “Obamacare,” the act was a comprehensive healthcare reform measure whose goal was making healthcare more available to millions of Americans.
The law mandates that all individuals obtain minimum essential health coverage and applicable large employers (ALEs) with an average of 50 or more full-time or full-time equivalent employees offer affordable, minimum value health insurance to at least 95% of these workers and their dependents.
Annual ACA Reporting Requirements for Employers
ALEs are subject to annual requirements for tracking and reporting to ensure healthcare coverage meets the act’s affordability standards and minimum value thresholds. Reporting also serves to confirm that minimum essential coverage has been offered to the requisite percentage of workers.
As in previous years, reporting for 2024 will involve filing information returns with the IRS and providing statements of healthcare coverage to employees by specific deadlines. Inaccurate information, missed deadlines, and failure to report will result in significant penalties and interest charges.
Non-ALEs with self-insured plans, including level-funded plans, also have annual tracking and filing requirements. There are no requirements for non-ALEs with fully insured plans.
Important 2025 Filing Deadlines for ACA Reporting
The charts below include upcoming ACA deadlines and forms for reporting healthcare coverage for the 2024 calendar year.
ALEs Sponsoring a Fully Insured Healthcare Plan
| Deadline | Action Required |
| 3/3/25 | Furnish Form 1095-C to every full-time employee. |
| 3/31/25 | File copies of Form 1095-C electronically with the IRS together with transmittal Form1094-C.
Note: Insurer completes Form 1095-B. |
ALEs Sponsoring a Self-Insured Healthcare Plan (includes Level Funded)
| Deadline | Action Required |
| 3/3/25 | Furnish Form 1095-C to all employees enrolled in the plan and COBRA participants. |
| 3/31/25 | File copies of Form 1095-C electronically with the IRS together with transmittal Form 1094-C. |
Non-ALEs Sponsoring a Self-Insured Healthcare Plan
| Deadline | Action Required |
| 3/3/25 | Furnish Form 1095-B to all employees enrolled in the plan. |
| 3/31/25 | File copies of Form 1095-B electronically with the IRS together with transmittal Form 1094-B. |
Non-ALEs Sponsoring a Fully Insured Healthcare Plan
No ACA reporting needed.
Pay Attention to Detail
Know the Rules for Mandatory Electronic Filing
IRS rules for filing returns and other documents electronically were amended in late 2023. Employers who file a total of 10 or more information returns, including Forms 1094-C and 1095-C, must now file forms electronically. This is a reduction from the previous 250-return threshold.
Employers filing electronically must either have a transmitter control code for the IRS’s AIR system or hire a third-party reporting service, such as NavigateHCR.
Be Aware of Higher Reporting Penalties
Penalty amounts have been adjusted upwards for reporting related to the 2024 tax year. Overall, employers will pay more for missed deadlines and inaccuracies.
Strategies to Simplify ACA Compliance
ACA reporting is complex, challenging and time-consuming. Collecting, verifying, and reporting data correctly requires in-depth knowledge and careful attention to detail. Inaccuracies and missed deadlines, even if inadvertent, can result in significant penalties.
NavigateHCR, a Partner Firm of U.S. Retirement & Benefits Partners, provides integrated solutions that simplify ACA compliance—from data verification to secure electronic filing— NavigateHCR’s team manages every aspect of the process to reduce or avoid penalties. Services include employee tracking, plan testing, year-end reporting, and electronic filing, not to mention plan communications and enrollment. Learn more about NavigateHCR and get out ahead of your ACA obligations in 2025.