Updated 10/23/2023

Do you print and mail your ACA 1095-Cs to the IRS? Or do you file them electronically? Be aware: the requirements for who can print and mail forms to the IRS rather than filing electronically (e-filing) have changed.

A new IRS proposed rule sought to phase out the paper-filing option by 2023, leaving it intact for only the smallest subset of employers. Specifically, the proposed rule would reduce the 250-count threshold to 100 for filings due in 2022. By 2023 and thereafter, the count threshold would decrease to an even smaller 10 filings. The proposed ruling also applies to worker forms like W-2 and 1099s. The IRS approved this proposed rule and consequently many employers are no longer able to file paper forms with the IRS.

Update: In 2023, an employer with 10 or more 1095-Cs may have to begin filing electronically.

On June 18, 2018, the IRS released a revenue bulletin (2018-25) that would affect your ability to print and mail forms to the IRS rather than e-file. The bulletin documents a proposed rule change to the “Filing Requirements for Information Returns Required on Magnetic Media (Electronically).” The regulations currently allow employers to consider only a particular form when determining whether that form must be filed electronically – in the case of ACA requirements, that form is the 1095-C. According to this bulletin, however “The proposed regulations would require that all information returns, regardless of type, be taken into account to determine whether a person meets the 250-return threshold and, therefore, must file the information returns electronically.” For 2023, this rule is effective!

For a small employer that is filing forms manually today, this could provide a significant burden if they now have to electronically file “all information returns.” This includes (but is not limited to):

  • 1099-DIV
  • 1099-MISC
  • 1099-INT
  • W-2
  • 1095-C
  • 1095-B

As a reminder, ACA filing requirements for each year are as follows:

March 2
Provide Form 1095-C to all ACA-defined, full-time employees

February 28
For paper filers: Mail transmittal, Form 1094-C and included 1095-Cs, to the IRS

March 31
For electronic filers: E-file Form 1094-C and included 1095-Cs with the IRS

Note: These dates may change each year depending on if they fall on a weekend, or if there is an IRS extension.
See ACA Deadlines at right for current year dates.

ACA Deadlines

As always, you can rely on Integrity Data to keep you abreast of ACA and other payroll compliance changes that may affect your organization. Follow our hashtag #ACAfluent on social media for the latest updates. We will be monitoring this proposed rule and update this article as the regulations are finalized. Also, know that we have many options for ACA compliance that include the ability to electronically file your ACA information returns. Please reach out to our team for more information.