With the start of a new year, there are several important reporting deadlines upcoming with respect to the federal Affordable Care Act (ACA), state individual mandate laws and W-2 reporting.

W-2 Reporting:

Employers must provide W-2s for the 2025 tax year to employees by January 31, 2026 (extended to the following business day if the regular deadline falls on a weekend), including applicable benefit related information:

• Health plan values (box 12, code DD)
• Employer and employee HSA contributions (box 12, code W)
• Taxable income for coverage provided during 2025 (i.e. life insurance in excess of $50,000, imputed income for domestic partner coverage)
• Employee / employer contributions to a dependent care flexible spending account or amounts contributed or directly paid by the employer for dependent care assistance (box 10). If corrections were made to a highly compensated employee’s (HCE) elections / contributions, only the reduced amounts should be reported.            

Affordable Care Act (ACA) Reporting:

The deadline to provide Forms 1095 to individuals is March 2, 2026.

• Form 1095-C must be provided by applicable large employers (ALEs) with 50 or more full-time equivalent employees (FTEs).
• Form 1095-B must be provided by issuers for fully insured plans and non-ALE employers (those with fewer than 50 FTEs) sponsoring self-insured plans.

New: Forms 1095 can now be provided upon request instead of being sent automatically.

• A clear, conspicuous and accessible notice must be posted on the employer’s website to let employees know the Forms will be provided upon request.
• The notice must provide an email address and physical address to which the request may be sent as well as a telephone number to use for asking questions.
• The notice must be posted by March 2, 2026 and remain on the website until October 15, 2026.
• If requested, the form must be provided no later than January 31, 2026 or 30 days after the request.

The deadline to file Forms 1094 and 1095 with the IRS is March 2, 2026 (if filing paper) or March 31, 2026 (if filing electronically).

• New: Employers who will file ten or more returns with the IRS for the year must file electronically via the AIR system.
• Filers will need to consider almost all information return types (1094, 1095, W-2, 1099) in determining whether they must file electronically.

State Individual Mandate Reporting:

Several states also have individual mandate reporting requirements that mirror federal ACA reporting requirements.

In most cases, state requirements to report coverage information to individuals can be satisfied by distribution of federal Forms 1095 in accordance with ACA regulations. Most states will also accept copies of IRS Forms 1094 and 1095 to satisfy state filing requirements. Many carriers and TPAs will file and distribute on the employer’s behalf.

California

• Employers must distribute federal Forms 1095 to covered California residents by January 31, 2026 (irrespective of the federal deadline for providing these forms).
• Employers must also file copies of federal Forms 1094 and 1095 with the California Franchise Tax Board by March 31, 2026 (automatic extension to May 31).
• More information is available on the website.

Massachusetts

• Employers must distribute MA Form 1099-HC to covered Massachusetts residents and file copies with the MA Department of Revenue by January 31, 2026.
• Most carriers and TPA’s will file and distribute on the employer’s behalf.
• More information is available on the website.

New Jersey

• Employers must distribute federal Forms 1095 (or NJ-1095) to covered New Jersey residents by March 2, 2026.
• Employers must also file copies of federal Forms 1095 with the Division of Taxation electronically by March 31, 2026.
• More information is available on the website.

Rhode Island

• Employers must distribute federal Forms 1095 to covered Rhode Island residents by March 2, 2026.
• Employers must also file copies of federal Forms 1094 and 1095 with the State of Rhode Island electronically by March 31, 2026.
• More information is available on the website.

District of Columbia

• Employers must distribute federal Forms 1095 to covered D.C. residents by March 2, 2026.
• Employers must also file copies of federal Forms 1094 and 1095 with the D. C. Office of Tax and Revenue electronically by April 30, 2026.
• More information is available on the website.

Client Actions:

• Clients who will be providing Forms 1095 upon request should ensure the required notice is posted to the website by March 2, 2026.
• Clients new to electronic filing of Forms 1094 and 1095 should carefully review the guides and other information available on the IRS website to ensure full understanding of technical and system requirements. Many payroll providers, TPAs or other third parties can assist with reporting.
• Piper Jordan is here to help. Please reach out to your client team if you have any questions or need assistance identifying potential ACA reporting resources.

Additional Resources:

ACA Reporting:

• Form 1094-C, Form 1095-C, 1094-B, 1095-B
• Instructions-Form 1094-C & 1095-C, Instructions-Form 1094-B & 1095-B
• Filing Guide for Software Developers and Transmitters
• ACA Returns Composition and Reference Guide
• Testing Package for Electronic Filers