More Employers Must File ACA Returns Electronically

Posted by BAS - 16 November, 2023


Simplify ACA Reporting with Our Affordable and Accurate Solution


The Affordable Care Act requires Applicable Large Employers (ALEs) to offer minimum essential coverage providing minimum value to their full-time employees. Employers must disclose coverage and offers of coverage on an IRS form furnished to full-time employees and covered employees. Employers also must communicate this coverage/offer of coverage information to the Internal Revenue Service (IRS). To fulfill ACA reporting obligations, employers utilize IRS Forms 1094-B/C and 1095-B/C. Specifically, the 1095 Form is furnished to employees, while the 1094 Form is transmitted to the IRS.

In prior years, employers had the option to file Forms 1094-C and 1095-C with the IRS by paper if they were filing fewer than 250 returns.  Employers making paper filings had to send the returns to the IRS by the end of February. Employers filing with the IRS electronically had to do so by the end of March. Only ALEs with 250 or more Forms 1095 were required to file electronically.

This paper-return filing threshold is changing for the 2023 reporting year. For the 2023 filing year, an employer may file paper returns only if the employer files 10 or fewer IRS returns per year of ANY type (W-2, 1099, 1095, etc.). This reduced threshold will require most employers to file their 1095 forms electronically with the IRS.

ACA reporting forms are filed electronically through the IRS Affordable Care Act Information Returns (AIR) system. The AIR system requires XML coding and a complex data set. Most employers (a) won’t be authorized to use the AIR system and (b) won’t have the date knowledge to prepare the XML schema according to IRS requirements.  

BAS is an approved IRS AIR system filer and is ready to help with your ACA filing obligations. For information about IRS reporting, contact your account manager or

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).

Topics: Health Care Reform (ACA), Affordable Care Act, MyEnroll360, HR & Benefits News, Affordable Care Act (ACA)

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