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May 27, 2025 By Mark

When and How to File ACA Forms Electronically

When and How to File ACA Forms Electronically

When and How to File ACA Forms Electronically: A Comprehensive Guide with ACA-Track

The Affordable Care Act (ACA) has brought significant reporting responsibilities for Applicable Large Employers (ALEs). From tracking employee hours to submitting the required forms to the IRS, compliance can quickly become complex. Fortunately, modern solutions like ACA-Track simplify this process, helping employers stay confident and compliant.

In this detailed blog post, we will explore when and how to file ACA forms electronically, unpacking the essentials of ACA reporting, compliance deadlines, and the benefits of using an expert ACA compliance service like ACA-Track.


Understanding ACA Reporting Obligations

What Are ACA Forms 1094-C and 1095-C?

  • Form 1095-C: Provided to employees, this form reports the health insurance coverage offered by the employer.

  • Form 1094-C: This is the transmittal form submitted to the IRS summarizing the 1095-C data.

ALEs with 50 or more full-time employees (including full-time equivalents) must file these forms annually. Failure to file correctly or on time can lead to penalties.


When to File ACA Forms Electronically

IRS Deadlines to Remember

  • Forms 1095-C to Employees: Typically due by January 31 following the reporting year (for example, January 31, 2026, for the 2025 coverage year). The IRS has occasionally granted extensions, but employers should plan for the January deadline to ensure compliance.

  • Forms 1094-C and 1095-C to IRS: Must be filed by March 31 if filing electronically (if filing on paper, the deadline is typically February 28). Since 2015, the IRS requires electronic filing for employers submitting 250 or more forms.

Who Must File Electronically?

  • Employers filing 250 or more 1095-C forms must file electronically.

  • Smaller employers can file on paper but may choose electronic filing for convenience.


How to File ACA Forms Electronically

Step 1: Obtain a Transmitter Control Code (TCC)

Before submitting ACA forms electronically, employers or their third-party service providers must apply for and obtain a TCC from the IRS. This code authorizes electronic transmission of ACA forms via the AIR (Affordable Care Act Information Returns) system.

  • The IRS recommends applying for the TCC at least 45 days before the filing deadline.

  • The application can take up to 45 days to process.

  • The TCC must be renewed annually for continued electronic filing.

Step 2: Prepare Data in IRS-Compliant XML Format

The IRS requires ACA form data to be submitted in an XML format that conforms to IRS AIR schema specifications.

  • The XML file must include all employee and coverage information as outlined in Forms 1094-C and 1095-C.

  • Employers often leverage ACA compliance software or third-party providers to generate these XML files accurately.

Step 3: Test and Validate the File

Before submitting, the file should be validated against IRS AIR schema requirements using IRS-approved software or services.

  • ACA-Track, for example, performs thorough monthly line code audits and error checks to ensure data accuracy.

  • Early testing reduces the risk of submission rejections or IRS penalties.

Step 4: Submit Electronically via the AIR System

Once validated and approved, the XML file is uploaded securely to the IRS AIR system.

  • ACA-Track facilitates secure electronic transmission of your ACA forms directly to the IRS.

  • The system generates confirmation receipts, so employers know their filings were successful.


Why Choose ACA-Track for ACA Electronic Filing?

Managing ACA compliance requires detailed data collection, constant monitoring, and precise reporting. ACA-Track is designed to streamline this entire process with features including:

  • Comprehensive Data Collection: Tracks hours for all employee types (full-time, part-time, variable hour) with integration to payroll and HRIS systems.

  • Monthly Line Code Audits: Automatically audits your data to catch errors early.

  • Electronic Filing Support: Generates IRS-ready XML files and submits them electronically.

  • State and Federal Reporting: Provides 1094-C and 1095-C reports for federal and state agencies.

  • Dedicated Client Success Advisor: Offers expert support throughout your ACA reporting process.


Key Benefits of Electronic ACA Filing

  • Accuracy and Error Reduction: Electronic filing with proper validation reduces errors common in manual paper filings.

  • Faster Processing: The IRS processes electronic submissions more quickly, avoiding mailing delays.

  • Audit Readiness: ACA-Track keeps all ACA compliance data in one secure location, simplifying responses to IRS audits.

  • Compliance Assurance: Timely electronic filing helps avoid costly penalties for late or incorrect submissions.


Final Tips for Successful ACA Electronic Filing

  • Start Early: Begin collecting and validating employee hours and coverage data well before the deadlines.

  • Obtain Your TCC Early: Don’t wait until the last minute to apply for your Transmitter Control Code.

  • Leverage Expertise: Consider ACA compliance software or trusted third-party services like ACA-Track to handle complex reporting.

  • Maintain Data Security: Ensure employee data is securely transmitted and stored in compliance with privacy standards.

  • Stay Updated: IRS rules and deadlines may change, so stay informed about the latest ACA guidance.


Conclusion

Filing ACA forms electronically is not only required for large employers but also offers significant advantages in accuracy, efficiency, and compliance. Navigating the complexities of ACA reporting can be challenging, but with a proven solution like ACA-Track, employers gain confidence and control over their compliance obligations.

From collecting accurate employee hours to filing IRS-compliant XML forms electronically, ACA-Track’s comprehensive platform and expert support make ACA compliance straightforward, secure, and hassle-free.


If you want to learn more about how to simplify your ACA compliance process, explore the full range of ACA Compliance Services offered by ACA-Track, and find the plan and pricing that fits your business needs.

Filed Under: ACA Compliance

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Information provided by PSST, LLC concerning the Affordable Care Act is not legal advice and should not be treated as such. If you have questions about how the Affordable Care Act will affect you as an employer, please consult legal counsel.

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