Filing Deadlines and Extensions for ACA Reporting

Applicable Large Employers and self-insured plan sponsors face annual IRS deadlines for distributing Forms 1095-C (or 1095-B) to covered individuals and transmitting the corresponding 1094-C (or 1094-B) transmittal forms to the IRS. Missing these deadlines exposes employers to per-return penalties under Internal Revenue Code Section 6721 and 6722. This page covers the statutory deadlines, the formal extension mechanism, how penalties escalate with timing, and the decision rules that determine which deadline applies to a given organization.

Definition and scope

ACA information reporting under Internal Revenue Code Sections 6055 and 6056 operates on two parallel deadline tracks: one for furnishing statements to individuals, and one for filing returns with the IRS (IRS, About Form 1094-C and 1095-C).

Furnishing deadline applies to sending Form 1095-C (or 1095-B) to each employee or covered individual. Filing deadline applies to submitting the complete 1094-C transmittal package — along with all associated 1095-C copies — to the IRS.

The scope of these obligations is set by employer size. Any employer that qualifies as an Applicable Large Employer (ALE) — generally 50 or more full-time-equivalent employees in the prior calendar year — must comply with Section 6056 reporting. Self-insured employers of any size carry the additional Section 6055 obligation. The full regulatory framework governing who qualifies as an ALE is detailed at Regulatory Context for ACA.

Both obligations are annual, keyed to the prior calendar year, and governed by IRS instructions updated each filing season. The IRS publishes the controlling instructions in Publication 5223 and the annual 1094-C/1095-C instruction set (IRS Instructions for Forms 1094-C and 1095-C).

How it works

The deadline structure follows a predictable annual cycle tied to the close of each calendar year reporting period.

  1. Furnishing to individuals — The baseline statutory deadline is January 31 of the year following the coverage year. For coverage year 2024, that date is January 31, 2025. The IRS has granted automatic extensions in prior years (pushing the furnishing deadline to March 3 in some cycles), but each extension is issued by separate IRS notice and is not guaranteed. Employers must consult the IRS notice published for the relevant tax year before assuming any extension applies.

  2. Paper filing with the IRS — Employers filing fewer than 10 returns (aggregate, across all information return types, under the threshold established by Treasury Decision 9972 effective for returns filed after January 1, 2024) must submit paper returns by February 28 of the filing year (TD 9972, IRS). The 10-return threshold was reduced from 250 by that regulation.

  3. Electronic filing with the IRS — Employers required to file electronically — or those choosing to do so — face a March 31 deadline. Electronic filing is mandatory for employers submitting 10 or more information returns in the aggregate. The IRS Affordable Care Act Information Returns (AIR) system handles electronic transmission (IRS AIR Program).

  4. Extension requests — A 30-day extension for IRS filing (not individual furnishing) is available by submitting Form 8809 on or before the original filing deadline. The extension is not automatic for ACA returns; filers must provide a reason. A second 30-day extension may be requested in limited circumstances but is not routinely granted.

Penalty rates under IRC §6721 (failure to file with the IRS) and §6722 (failure to furnish to individuals) are tiered by timing. For 2024 returns, the per-return penalty is $310 for failures corrected after August 1, $120 for failures corrected between 31 days late and August 1, and $60 for failures corrected within 30 days of the due date, with annual caps that vary by employer size (IRS, General Instructions for Certain Information Returns 2024).

Common scenarios

Scenario 1 — Large employer, electronic filer, no extension needed.
An ALE with 400 employees files electronically through the AIR system. The furnishing deadline is January 31 (or the IRS-granted extension date in the applicable notice). The electronic filing deadline is March 31. No Form 8809 is required.

Scenario 2 — Mid-size employer, paper filer under the old threshold, now required to e-file.
An employer with 12 ACA returns who previously filed on paper must now file electronically under the revised 10-return aggregate threshold effective after January 1, 2024. The March 31 electronic deadline applies. Failure to transition to electronic filing is itself a filing defect subject to §6721 penalties.

Scenario 3 — Good-faith relief for first-time filers.
The IRS has historically provided transitional good-faith relief for employers that made good-faith efforts to comply with reporting requirements, even if submitted forms contained errors. This relief does not extend to employers who fail to file or furnish entirely. Employers relying on this protection should document their compliance process. Good-faith relief provisions are announced by annual IRS notice and are not codified permanently in the IRC.

Scenario 4 — State-level filing obligations.
California, New Jersey, Rhode Island, Massachusetts, Vermont, and Washington, D.C. maintain their own individual mandate reporting requirements with separate furnishing and filing deadlines that may differ from federal dates. California's deadline for employer-sponsored coverage reporting to the Franchise Tax Board, for example, is set by California Revenue and Taxation Code Section 61005. Employers with operations in these jurisdictions must track both federal and state deadlines independently.

Decision boundaries

Determining which deadlines and extension options apply requires working through a structured set of threshold questions.

Is the employer an ALE?
Only ALEs are subject to Section 6056 obligations. Non-ALE self-insured sponsors carry Section 6055 duties only, using Forms 1094-B and 1095-B. The ALE determination is covered in detail at the ACA compliance resource index.

How many information returns are filed in the aggregate?
The 10-return threshold under TD 9972 counts across all information return types — W-2s, 1099s, and ACA forms combined. An employer filing 8 W-2s and 4 1095-Cs has 12 returns total and must file electronically.

Has a furnishing extension been granted by IRS notice for the tax year?
Furnishing extensions are not statutory; they are discretionary IRS notices. Employers should not assume the January 31 furnishing date has been extended without locating the relevant IRS notice for the specific coverage year.

Is a filing extension needed?
Form 8809 must be filed on or before the original paper or electronic deadline. It cannot be filed retroactively. The extension covers only IRS filing, not individual furnishing. If an employer misses the furnishing deadline, no extension mechanism restores the January 31 date.

Are state-level obligations present?
Employers in California, New Jersey, Rhode Island, Massachusetts, Vermont, and Washington, D.C. must treat state deadlines as independent compliance obligations, not extensions of the federal timeline.

Obligation Baseline Deadline Extension Available Extension Form
Furnish 1095-C to individuals January 31 Yes (by IRS notice only) None — IRS must issue notice
Paper filing with IRS February 28 Yes — 30 days Form 8809
Electronic filing with IRS March 31 Yes — 30 days Form 8809
California FTB reporting January 31 (state) Per FTB instructions FTB-specific

References

The law belongs to the people. Georgia v. Public.Resource.Org, 590 U.S. (2020)