ACA Compliance

The IRS filing deadline for Forms 1094-C and 1095-C, and how extensions work.

Employers file Form 1094-C with the 1095-Cs on paper or electronically. For 2025 reporting the dates were March 2, 2026 on paper and March 31, 2026 electronically, and Form 8809 adds an automatic 30 days.

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The Dates

When the filing is due.

Paper Filing

For 2025 reporting, paper filings were due March 2, 2026, because the usual date fell on a weekend and rolls to the next business day.

Electronic Filing

Electronic filings were due March 31, 2026 for 2025 reporting.

The Weekend Rule

Whenever a due date falls on a weekend or legal holiday, it moves to the next business day.

Extensions

What can and cannot be extended.

Form 8809

A 30-day automatic extension to file with the IRS is available by filing Form 8809 on or before the due date.

A Second 30 Days

Under certain hardship conditions, an additional 30 days may be requested.

Furnishing Is Separate

The extension to file with the IRS does not extend the date to furnish employees, which the IRS handles separately.

Penalty Tiers Run From the Due Date

The 30-day and August 1 penalty tiers are measured from the required filing date.

Common Questions

Quick answers.

Short answers. This is general information, not legal or tax advice.

Is the IRS Date the Same as the Employee Date?

They were the same day for 2025 reporting, March 2, 2026 for paper, but they are separate requirements with separate penalties.

Do We Have to File Electronically?

Yes, if you file 10 or more information returns of any kind in the year. W-2s and 1099s count toward the ten.

What if We Miss It?

Section 6721 applies to each return filed late: $60, $130 or $340 depending on when the correct return is filed.

Sources

Where the rules and figures come from.

Each figure on this page comes from the source below. Amounts are indexed or updated over time, so confirm current figures before relying on them.

Instructions for Forms 1094-C and 1095-C

Due dates, extensions, the posted notice option, e-filing and the $100 safe harbor.

Read the Source

26 U.S.C. 6721

Failure to file correct information returns.

Read the Source

IRS Publication 1586

Penalty tiers and annual caps for returns due in 2026.

Read the Source

Let’s Get to Work

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.

What to send

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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