2027 ACA reporting deadlines: what is due, and when.
Applicable large employers report on the prior year in early 2027. This page lists the dates, the one change that spares most employers a mailing, and the figures that move each year. Dates are the rule as we read it; confirm against the current IRS instructions before you file.
Four dates cover most of it.
Reporting in 2027 covers the 2026 calendar year. When a due date falls on a weekend, it moves to the next business day.
Furnish Forms 1095-C
January 31, 2027 is the standard date to give each full-time employee a statement. That is a Sunday, so it moves to Monday, February 1.
The IRS automatically allows a 30-day extension for furnishing, which takes the deadline to about March 2, 2027. No request is needed.
File with the IRS on paper
February 28, 2027 for paper filing of Form 1094-C with the 1095-C forms. That is a Sunday, so it moves to Monday, March 1.
Paper filing is only available to employers filing fewer than ten information returns in total.
File with the IRS electronically
March 31, 2027. Electronic filing is required once an employer files ten or more information returns of any kind in the year. W-2s and 1099s count toward the ten, so most applicable large employers must e-file.
Skip the mailing, if you qualify
An employer may instead post a clear, conspicuous notice that employees can request a Form 1095-C. The notice goes up by the furnishing due date and stays up through October 15. A requested form must be furnished within 30 days of the request.
Filing with the IRS is unchanged. Some states have their own furnishing rules that this federal relief does not override.
Who files, and who does not.
Applicable large employers
Employers with 50 or more full-time and full-time-equivalent employees on average in the prior year file Form 1094-C and a Form 1095-C for each full-time employee. This is the ACA employer mandate threshold.
Self-insured employers under 50
A smaller employer that self-funds its plan files a different set of forms, 1094-B and 1095-B, to report coverage. A fully insured small employer generally does not file, because the carrier does.
Level-funded plans
A level-funded plan is self-funded up to the attachment point, so reporting responsibility sits with the employer, not the carrier. Confirm who files before the year closes, not in February.
The affordability percentage for 2027.
Affordability is the test behind the line 16 codes in Part II of the 1095-C, so the figure matters even to employers who do not expect to owe anything.
2026 and 2027
For plan years beginning in 2026 the percentage is 9.96%. For plan years beginning in 2027 it is 10.22% (IRS Rev. Proc. 2026-26).
What it is measured against
The employee’s cost for the lowest-priced self-only option that meets minimum value, using one of the safe harbors: W-2 Box 1 wages, rate of pay, or the federal poverty line.
Why it matters in January
The codes on each 1095-C are decided by what was offered each month of 2026. Collect the offer, enrollment and employee-contribution history by month now, while payroll and enrollment systems still agree.
Common questions about the reporting deadline.
Do we still have to mail every 1095-C?
Not if you use the on-request alternative and post the required notice. Many employers still mail them because it avoids handling requests; that is a choice, not a requirement.
What if we miss the date?
Late or incorrect filings can draw IRS penalties, and the amounts are indexed each year. Corrections and penalty relief have their own procedures, so call us before you respond to an IRS letter.
Who prepares the forms for us?
Many clients run reporting through their benefits administration platform or payroll provider. We check the codes against what was actually offered before they go out.
Send us your renewal.
We’ll tell you whether it looks competitive, where we see opportunity, and the five questions we’d put to your carrier. No cost, and no obligation to move anything.
The renewal letter
Your current plan summary
Contribution split by tier
Enrolled counts by tier
Four documents — two more if your group is 50 or more. Nothing else; every extra one is a reason to postpone.
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