The IRS has released a draft version of the 2026 Form 1095-C, providing employers and ACA reporting vendors with an early look at next year's reporting form. For most employers, the draft form will look very familiar, as it contains few substantive changes from the version used for 2025 reporting.
Form 1095-C is used by applicable large employers (ALEs) to report offers of health coverage to full-time employees and to help the IRS administer the Affordable Care Act's employer shared responsibility provisions. Employees may also use information reported on the form when determining eligibility for premium tax credits through the Health Insurance Marketplace.
The draft form continues to include the existing ACA offer-of-coverage codes used on Line 14, including the various codes associated with Individual Coverage Health Reimbursement Arrangements (ICHRAs). These codes address affordability determinations based on an employee's residence ZIP code or primary worksite ZIP code and reflect the continued availability of ICHRA-based coverage options.
The draft also continues to reserve several reporting codes for future use, suggesting that while the IRS may make reporting changes in future years, no significant coding changes have been introduced for 2026.
Although the form itself appears largely unchanged, employers should not overlook the importance of ACA reporting. Recent increases to employer shared responsibility penalties mean that inaccurate reporting, coding errors, or eligibility tracking mistakes can become increasingly costly.
Now is a good time for HR and benefits teams to review:
- Full-time employee measurement and tracking procedures
- Coverage offer documentation
- ACA affordability testing methodologies
- Payroll and enrollment data accuracy
- Reporting processes and coding practices
The release of the draft form is an encouraging sign that employers are unlikely to face major ACA reporting changes for 2026. However, maintaining accurate employee eligibility and coverage records remains an important part of avoiding penalties and ensuring successful ACA compliance.
For information about BAS’ ACA Data Collection and Reporting services, contact your account manager or solutions@basusa.com.
Benefit Allocation Systems (BAS) provides best-in-class, online solutions for: Employee Benefits Enrollment; COBRA; Flexible Spending Accounts (FSAs); Health Reimbursement Accounts (HRAs); Leave of Absence Premium Billing (LOA); Affordable Care Act Record Keeping, Compliance & IRS Reporting (ACA); Group Insurance Premium Billing; Property & Casualty Premium Billing; and Payroll Integration.
MyEnroll360 can Integrate with any insurance carrier for enrollment eligibility management (e.g., Blue Cross, Blue Shield, Aetna, United Health Care, Kaiser, CIGNA and many others), and integrate with any payroll system for enrollment deduction management (e.g., Workday, ADP, Paylocity, PayCor, UKG, and many others).
This article is for informational purposes only and is not intended as legal, tax, or benefits advice. Readers should not rely on this information for taking (or not taking) any action relating to employment, compliance, or benefits. Always consult with a qualified professional before making decisions based on this content.
