ACA 1095 Filing for Employers
- BenefitGuru
- Jan 7, 2025
- 3 min read
Updated: Jan 14
Employers with More than 50 Full Time Equivalent Employees (including commonly owned companies) or who offer a Self-Funded Medical Plan (of any size) Must Report Health Coverage Offered to the IRS for 2025.

Employers and Carriers will be required to provide reporting on the health coverage they offer so the IRS can verify that employers are meeting their responsibility and ensure that individuals who request premium tax credits are entitled to them. Employers who offer medical coverage and have more than 50 Full-Time Equivalent Employees are required to file 1094C & 1095C. Employers on a self-funded medical plan (of any size) must file 1094B & 1095B to those enrolling.
For the 2025 reporting year, New Jersey, Washington, DC, California, and Rhode Island have implemented individual mandates for health coverage that require every state resident to have health insurance, obtain an exemption, or pay a penalty (shared responsibility payment) with their state income tax return. Employers and providers of health coverage to NJ, DC, CA, and RI residents must file 1095 forms to the state(s). They only accept electronic filing, no paper forms.
2025 Forms 1095 are due to employees by March 2, 2026. If you are a level-funded plan, notice to employees is due on January 31 (or within 30 days of individual request). 1094 & 1095’s are due to the IRS by March 2, 2026 (or March 31, 2025, if filing electronically)
Link for More: Employer Pay or Play Basics
Calculate your Full Time Equivalent Employee Count (Large Group Applicable Large Employer - ALE):
Here are two online calculators to help you determine your Full-Time Equivalent count and qualify for these requirements. If you are classified as an ALE for 2023 you need to prepare and file a 1095 this year. Click the links below
Small Group Self-Funded Medical Plan
If you offer a Self-Funded medical plan to your employees, regardless of size, you will need to file a 1094B & 1095B. Instruction Links are listed below.
Paperwork Reduction Act of 2024
Employers can make 1095’s available upon request, rather than mailing a copy out to each employee. Also, Employers can send out the 1095 electronically if employees consent to receive it electronically. For more information, click the links below:
Is My Plan Affordable?

ALE Employers are required to offer coverage that provides minimum value to 95% of their full-time employees. Also, the coverage must be affordable. There are three Safe Harbors to calculate affordability. You should use the same method from year to year. Federal Poverty (FPL) Safe Harbor, W2 Safe Harbor, and Rate of Pay Safe Harbor.
Need to find out if your plan is affordable?
How Can I Get More Details About 1095 Reporting?

I need help! What Resources are available to help me produce my 1095’s and file them with the IRS this year?
We have compiled the following list of resources to help you complete and file your 1095:
Employee Navigator: If you use Employee Navigator for enrollment, you can complete your 1095 under the ACA tab, through a 3rd party Nelco. You will need to import some additional information.
HR Service Inc.
Email: solutions@hrserviceinc.com Phone: (833)685-8400x1
Learn More: https://www.hrserviceinc.com/aca-reporting/
Ez1095 (downloadable software so you can do it yourself and mail if you are familiar with 1095 and codes)
ACA Compliance Services (online, full service)
Phone: 877-959-3953
CXC 1095Xpress (online service at a low fee if you don’t have variable hour employees or need to calculate measuring period)
IRS Information on the Pay or Play rules
Robin Sellers
Consultant / Insurance Agent
Robin@Benefitguru.com



