New regulations issued by the Internal Revenue Service (IRS) will require most employer-sponsored benefit plan filings to be completed electronically beginning next year. These regulations impact filings associated with the Affordable Care Act (ACA) as well as other IRS returns and statements.

• Previously, employers that filed 250 or more returns in a calendar year were required to file electronically.
• Additionally, under the previous rules, the threshold of 250 returns or statements applied to each filing category individually. In other words, an employer required to file 150 Forms 1095-C and 150 Forms W-2 would not be required to file electronically.
• The new regulations reduce the electronic filing threshold to 10 or more returns, in aggregate. Any employer that files a total of 10 or more covered returns annually will be required to file electronically.
• The new electronic filing requirements are effective for any filings due after December 31, 2023 (i.e., beginning in 2024).
• The regulations also impact the filing of 1099, 5498, and 5500 forms. The economic hardship exception that previously applied to the filing of 5500s will no longer apply.
• Employers should consult a tax professional if they have questions about how these regulations impact them.