ACA Electronic Information Return Filing Deadline Is June 30

Author: Rena Pirsos, XpertHR Legal Editor

June 27, 2016

The IRS is urgently reminding self-insured employers, applicable large employers and providers of health coverage that the due date to electronically file information returns in compliance with the Affordable Care Act (ACA) is this Thursday, June 30. This includes electronic filing of the 1094 and 1095 series of forms.

While the deadline to provide information returns to employees or responsible individuals was March 31, and the deadline to file paper information returns was May 31, electronic filers were given more time.

The IRS has issued the following chart showing the due dates for each return and explaining which entities must file them. The IRS notes that this chart applies only to reporting in 2016 for coverage in 2015 and that the due dates will be different in future years. Information about these future dates is provided in IRS Notice 2016-04.

Electronic Filing Due Dates in 2016 for...

Action Applicable Large Employers - Including Those That are Self-Insured Self-Insured Employers That Are Not Applicable Large Employers Coverage Providers - Other Than Self-Insured Applicable Large Employers*

Electronically File 1094-B and 1095-B with the IRS


Not Applicable**


June 30*


June 30*

Electronically File 1094-C and 1095-C with the IRS


June 30*


Not Applicable


Not Applicable

*If an employer files 250 or more Forms 1095-B or 1095-C, then the employer must electronically file them with the IRS. Electronically filing ACA information returns requires an application process separate from other electronic filing systems. Additional information about electronic filing of ACA Information Returns is on the Affordable Care Act Information Reporting (AIR) Program page (on and in IRS Publications 5164 and 5165.

**Applicable large employers that provide employer-sponsored self-insured health coverage to non-employees may use either Form 1095-B or 1095-C to report coverage for those individuals and other family members.