2026 ACA Form 1095 Distribution and Filing Deadlines - HR ALERTS

2026 ACA Form 1095 Distribution and Filing Deadlines

Who This Applies To

This alert applies to Applicable Large Employers (ALEs), generally employers that averaged 50 or more full-time and full-time equivalent employees during the prior calendar year.

Employee Distribution

ALEs must provide Form 1095-C to full-time employees and other covered individuals.

• The IRS has extended the employee distribution deadline to March 2, 2026

• Employees do not need Form 1095-C to file their individual tax returns

• Forms may be delivered electronically if proper consent is on file

IRS Filing Deadlines

ALEs must file ACA reporting forms with the IRS:

• Paper filing: due February 28, 2026

• Electronic filing: due March 31, 2026

Electronic filing is required for employers submitting 10 or more forms.

Form 1094-C Filing

Vida HR files Form 1094-C as part of the ACA reporting process for applicable clients. Form 1094-C serves as the required transmittal and employer level summary submitted with Forms 1095-C.

Corrected Forms

If errors are identified after distribution or filing, corrected Forms 1095 should be issued as soon as possible to reduce the risk of IRS notices or penalties.

System Note

For clients using isolved for benefit administration, ACA reporting files are generated based on the data in the system. Accurate employee status, hours, and offer of coverage information is critical to ensure correct reporting.

Get day-to-day updates on 2026 ACA Form 1095 Distribution and Filing Deadlines visit the Vida HR Knowledge Center (Vida HR Clients Exclusive).