Employer Guide & Glossary
STATE ACA MANDATES
When passed IN 2010, the AFFORDABLE CARE ACT [ACA] required individual US citizens to purchase & maintain qualifying health insurance coverage — or face a federal penalty. By reducing these penalties to zero in 2019, the federal TAX CUTS & JOBS ACT [TCJA] effectively repealed this ACA individual mandate [as opposed to the ACA EMPLOYER MANDATE].
Eleven US states have since formally eliminated the original federal ACA mandate on individuals and implemented [or are in the process of implementing] their own STATE ACA MANDATES on individuals in its place.
It is under these eleven STATE ACA MANDATES that individuals residing in these states are now required to purchase & maintain health insurance — or face state penalties. This arrangement impacts ACA reporting for employers with employees in certain of those states.
Other than in Massachusetts, which has its own reporting system, these states typically piggyback on IRS FORMs 1095 & 1094 to gather information about the health coverage of their residents. This means that for certain states, in addition to ACA reporting to the IRS, APPLICABLE LARGE EMPLOYERS [ALEs] must also report health coverage to the relevant state governments for any full-time employees resident in those states.
NOTE: EMPLOYER VS EMPLOYEE LOCATION. The employer organization's location is not the deciding factor concerning state ACA reporting obligations. The deciding factor is where the employee lives. This adds a layer of complexity for employers with employees who work remotely or commute to work from other states.
What follows is a CHECKLIST of the eleven mandating states, the ACA forms [where specified] to be distributed and filed, and the known deadlines.
| STATE | FORMS TO FILE | DEADLINES |
|---|---|---|
| CA |
IRS Employer Form 1094-C IRS Employee Forms 1095-B & C |
Distribution to employees: Feb 02.2026 State filing: March 31.2026 |
| CT | Not specified | -- |
| DC |
IRS Employer Form 1094-C IRS Employee Forms 1095-B & C |
Distribution to employees: March 02.2026 State filing: April 30.2026 |
| HI | Not specified | -- |
| MD | Not specified | -- |
| MA | MA 1099-HC Form |
Distribution to employees: Feb 02.2026 State filing: Also Feb 02.2026 |
| MN | Not specified | -- |
| NJ |
IRS Employer Form 1094-C IRS Employee Forms 1095-B & C |
Distribution to employees: March 02.2026 State filing: March 31.2026 |
| RI |
IRS Employer Form 1094-C IRS Employee Forms 1095-B & C |
Distribution to employees: March 02.2026 State filing: March 31.2026 |
| VT | See note below.* | -- |
| WA | Not specified | -- |
*Vermont has retained the federal requirement for employers to distribute FORMS 1095; the federal deadlines apply of Feb 02.2026 for furnishing & March 31.2026 for e-filing.
This table has not been updated for TY2026 [reporting in 2027], pending further information releases from mandated states. If you have questions about STATE ACA MANDATES & REPORTING or any other aspect of ACA compliance, please contact BENEFITSCAPE, the leading ACA specialist.
BENEFITSCAPE provides best-in-class ACA COMPLIANCE SERVICES, including intelligent, system-agnostic ACA_RegTech, to 1000s of employers of all sizes, in all sectors, across all states, and on all major Payroll and HCM systems.