Beginning January 1, 2024, virtually all employers will be required to file ACA reporting Forms 1094-B/1095-B and 1094-C/1095-C electronically. On February 21, 2023, the IRS published final regulations to the Taxpayer First Act of 2019, significantly expanding the e-filing mandate for certain tax returns.
Specifically, Forms 1094-B/1095-B and 1094-C/1095-C must be filed electronically if the total number of information returns (including Forms W-2 and 1099s) an employer files that year exceeds 10. As a result, all applicable large employers (ALEs) and most non-ALE self-insured employers completing ACA reporting will be required to do so electronically. If an employer demonstrates undue hardship, such as increased filing costs, the IRS may waive the e-filing requirement. Applications for an e-filing waiver are made via Form 8508.
Employers currently completing ACA reporting via paper mailing should consult with their tax advisor on e-filing requirements in 2024, discuss any potential undue hardship waiver and, if required, prepare to complete ACA reporting electronically. While employers may use third-party vendors to e-file on their behalf, they remain liable for any reporting failures.
For further information regarding the upcoming filing changes, please also see our February 28, 2023, article.
PPI Benefit Solutions does not provide legal or tax advice. Compliance, regulatory and related content is for general informational purposes and is not guaranteed to be accurate or complete. You should consult an attorney or tax professional regarding the application or potential implications of laws, regulations or policies to your specific circumstances.
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