ACA Compliance Checklist for HR Teams in 2025: What You Need to Know

The Affordable Care Act (ACA) continues to shape how employers manage health benefits and compliance reporting. For HR teams, staying on top of ACA requirements can feel like navigating a complex maze — especially as regulations evolve and IRS deadlines loom. This detailed ACA compliance checklist for 2025 will help HR professionals ensure their organizations avoid costly penalties and streamline reporting processes.

And if you want to simplify the journey, ACA-Track offers a trusted, comprehensive ACA compliance solution designed for HR teams and organizations of all sizes. Let’s dive in.

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Understanding ACA Basics: Who Must Comply?

Before we get into the checklist, here’s a quick refresher:

• Applicable Large Employers (ALEs) are companies with 50 or more full-time equivalent (FTE) employees, including a mix of full-time and part-time workers combined into an FTE count. ALEs must comply with ACA’s employer shared responsibility provisions.

• A full-time employee is someone working an average of at least 30 hours per week or 130 hours per month.

• Tracking variable hour and part-time employees’ actual hours worked is crucial to determine if they meet the full-time threshold and thus qualify for health coverage offers.

Failing to track these hours accurately can expose your company to penalties if employees claim Marketplace premium tax credits when your company should have provided coverage.

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The 2025 ACA Compliance Checklist for HR Teams

1. Identify Your ALE Status

• Confirm your employee count based on last year’s workforce.

• Use the IRS formula to calculate full-time equivalents, considering part-time hours capped at 120 hours per employee per month.

2. Accurately Track Employee Hours

• Implement systems that capture actual hours worked for all employee types (full-time, part-time, variable-hour).

• Collect data from multiple sources: payroll, time clocks, mobile entries, manual timesheets.

• Keep detailed records for each measurement period to identify who meets full-time status.

3. Monitor Eligibility and Events

• Set alerts for employees approaching full-time thresholds.

• Track changes such as new hires, terminations, leaves, waivers, or rehires.

• Adjust coverage offers accordingly to stay compliant.

4. Prepare and Distribute IRS Reporting Forms

• Generate Forms 1095-C for every full-time employee showing coverage offered.

• Submit Form 1094-C transmittal to the IRS accurately and on time.

• For self-insured employers, complete Part III of Form 1095-C for employees and dependents enrolled.

5. Meet IRS Deadlines

• Provide 1095-Cs to employees by January 31 (or next business day).

• File 1094-C and 1095-Cs with the IRS by March 31 electronically or February 28 if filing by paper.

• If you have 250+ employees, electronic filing is mandatory.

6. Maintain Data Security and Privacy

• Protect all employee data with encryption and secure transfer protocols.

• Limit access to sensitive information and train staff on data privacy best practices.

• Ensure third-party providers comply with security standards (SOC 2, SSAE 16).

7. Respond Promptly to IRS Notices

• If you receive an IRS Letter 226-J (penalty notice), act quickly.

• Review all employee subsidy data and coverage offers.

• Consult legal or ACA compliance experts to dispute inaccuracies.

• Submit responses within 30 days of the letter.

8. Leverage Technology to Simplify Compliance

• Use ACA compliance software to automate tracking, reporting, and error correction.

• Look for features like customizable dashboards, snapshot data views, and detailed audit trails.

• Integrate with your payroll, HRIS, and financial systems for seamless data flow.

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Why ACA-Track is an Essential Partner for HR Teams in 2025

Navigating ACA compliance requires precision, up-to-date knowledge, and efficient data management. That’s where ACA-Track comes in.

ACA-Track is a cloud-based, secure, and user-friendly ACA compliance solution trusted by HR professionals to:

• Collect accurate hours worked data from all employee types across multiple systems.

• Monitor employee eligibility and provide advance alerts for key events.

• Report confidently with comprehensive, IRS-ready 1094-C and 1095-C forms, including electronic filing.

• Perform monthly line code audits on 1095-Cs to catch and fix errors early.

• Track variable hour employees easily, avoiding costly penalties.

• Offer dedicated client success advisors to simplify compliance.

• Maintain all ACA compliance data in one centralized, secure location — essential for IRS audits or state healthcare exchange requests.

With over 30 years of expertise in HR, payroll, and benefits software development, ACA-Track’s robust platform meets the needs of organizations of all sizes and complexities.

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Additional Tips for HR Teams in 2025

• Regularly review and update your ACA policies to reflect new IRS guidance and legislative changes.

• Ensure your benefits, payroll, finance, and HR teams collaborate closely for data accuracy.

• Stay ahead of deadlines with automated reminders and reporting workflows.

• Document all employee communications regarding coverage offers and waivers.

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Conclusion

ACA compliance in 2025 requires detailed tracking, precise reporting, and a proactive approach to employee data management. By following this checklist, HR teams can minimize risks, avoid penalties, and confidently meet their employer responsibilities under the ACA.

To make this process simpler and more reliable, explore how ACA-Track can help your organization collect, monitor, and report ACA compliance data seamlessly — saving time, reducing errors, and ensuring peace of mind.

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Ready to take the complexity out of ACA compliance? Visit ACA-Track today to learn how their proven solutions can fit your business needs and keep you audit-ready in 2025 and beyond.