Yes. The filing burden in Q1 2016 isn’t just for employers with 100 or more FTEs. Although the tax liability for coverage noncompliance in Calendar Year 2015 is just for employers with 100 or more FTEs, employers with 50 to 99 FTEs must meet the IRS reporting component of the Affordable Care Act for CY2015.
The IRS nonfiling penalty for disregarding required information reports, including 1095-C/1094-C returns, is $500 per required form.
Therefore, it is very important for these employers, too, to be implementing an ACA solution now.
The urgency is greater for employers with 50 to 99 FTEs who are in industries vulnerable to ACA penalties. The financial consequences of procrastinating past October 1, 2015, are of white-knuckle importance for employers with 50 to 99 FTEs because their penalty assessment period for coverage noncompliance begins January 1, 2016.