Employer Guide & Glossary
IRS DEADLINES & IRS AIR FILING
The key IRS ACA reporting deadlines for TY24 [filing in 2025] were as follows:
MARCH 3, 2025: DEADLINE to furnish IRS FORMs 1095-C to individual eligible employees. This date took in account that 2024 is a leap year.
MARCH 31, 2025: DEADLINE to e-file IRS FORMs 1095-C & 1094-C plus all other required ACA documentation to the IRS.
Click here for a list of all STATE ACA MANDATE deadlines
Click here for a comprehensive guide to IRS CODES for FORM 1095-C.
- NOTE: NO MORE PAPER FILING. As of TY23 the IRS required all ALEs [absent very few unusual circumstances] to e-file FORMs 1095-C & all other ACA documentation via the IRS ACA Information Returns System [IRS AIR].
- NOTE: TRANSMITTER CONTROL CODES. Only IRS certified e-filers can file ACA reports to the IRS AIR. Confirm well in advance of filing that you [or your specialist ACA vendor] have the certification of an IRS TRANSMITTER CONTROL CODE [TCC].
HCM vs. IRS DEADLINES
Please note that HCM system providers may set earlier deadlines than these for processing ACA compliance. These HCM DEADLINES are not the IRS DEADLINES but are designed to enable bulk processing of data to the IRS. So even if these deadlines
are missed, individual company filing is usually still possible.
IRS LATE FINES FOR MISSING TY24 [FILING 2025] DEADLINES:
- UP TO 30 DAYS LATE:
IRS PENALTY = $60 PER RETURN;
with a maximum penalty of $630,500 per ALE. - OVER 30 DAYS LATE BUT BEFORE AUG 1, 2024:
IRS PENALTY = $130 PER RETURN;
with a maximum penalty of $1,891,500 per ALE. - AFTER AUG 1, 2024:
IRS PENALTY = $310 PER RETURN;
with a maximum penalty of $3,783,000 per ALE.
- NOTE: IRS PENALTY FOR NON-FILING = $660 PER RETURN
with no limitation on maximum if the IRS determines failure to file is intentional disregard.
If you have questions about these ACA IRS DEADLINES & PENALTIES or any other aspect of the ACA process, please contact BENEFITSCAPE, the leading ACA specialist.