Employer Guide & Glossary
IRS DEADLINES & IRS AIR FILING
The key projected IRS ACA reporting deadlines for TY26 [filing in 2027] are as follows:
MARCH 2, 2027: To furnish IRS FORMs 1095-C to individual eligible employees.
MARCH 31, 2027: To e-file IRS FORMs 1095-C & 1094-C plus all other required ACA documentation to the IRS. [Paper filing: FEB 28]
Click here for a list of all STATE ACA MANDATE deadlines
Click here for a comprehensive guide to IRS CODES for FORM 1095-C.
- NOTE: NO MORE PAPER FILING. As of TY23 the IRS required all ALEs [absent very few unusual circumstances] to e-file FORMs 1095-C & all other ACA documentation via the IRS ACA Information Returns System [IRS AIR].
- NOTE: TRANSMITTER CONTROL CODES. Only IRS certified e-filers can file ACA reports to the IRS AIR. Confirm well in advance of filing that you [or your specialist ACA vendor] have the certification of an IRS TRANSMITTER CONTROL CODE [TCC].
HCM vs. IRS DEADLINES
Please note that HCM system providers may set earlier deadlines than these for processing ACA compliance. These HCM DEADLINES are not the IRS DEADLINES but are designed to enable bulk processing of data to the IRS.
So even if HCM deadlines are missed, individual company filing is usually still possible.
IRS LATE FINES FOR MISSING TY25 [FILING 2026] DEADLINES ARE:
- UP TO 30 DAYS LATE:
IRS PENALTY = $60 PER RETURN;
with a maximum penalty of $683,500 per ALE. - OVER 30 DAYS LATE BUT BEFORE AUG 1, 2026:
IRS PENALTY = $130 PER RETURN;
with a maximum penalty of $2,049,000 per ALE. - AFTER AUG 1, 2026:
IRS PENALTY = $340 PER RETURN;
with a maximum penalty of $4,098,500 per ALE.
NOTE: IRS PENALTY FOR NON-FILING = $680 PER RETURN
with no limitation on maximum if the IRS determines failure to file is intentional disregard.
For information about IR CODE 4980H(a) and IR CODE 4980H(b) penalties, go to the ACA CENTRAL section on IRS226J PENALTY LETTERS.
If you have questions about these ACA IRS DEADLINES & PENALTIES or any other aspect of the ACA process, please contact BENEFITSCAPE, the leading ACA specialist.