Compliance Reminder | ACA Reporting Obligation and Due Dates

Compliance Reminder | ACA Reporting Obligation and Due Dates

If you are an Applicable Large Employer (ALE) and offer medical benefits to your employees, you are required to complete IRS forms 1095-C and 1094-C, and report appropriately to the IRS and to your employees. The reporting indicates which full-time employees were offered medical coverage during 2022.

An ALE is any employer who averaged 50 or more full-time employees or full-time equivalents in calendar year 2021.


Employers with less than 50 employees and who had a self-funded or level-funded medical plan for their employees during 2022, must complete ACA reporting as well.  Please check with your medical insurance carrier to see what type of support they offer with producing the 1095 form and filing with the IRS.  Many carriers have the 1095 forms available for download through your insurance carrier portal.  If you have questions, your Brinson Account Executive can help!

IRS Due Dates

  • February 28, 2023: If mailing 1094/1095s to the IRS (rules apply)
  • March 2, 2023: 1095s to employees/responsible individuals
  • March 31, 2023: If E-filing 1094/1095s to the IRS electronically

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