Year-end processing is quickly approaching, and that means it’s time to stay on top of Affordable Care Act (ACA) reporting deadlines. You can prepare by catching up on new information and codes regarding 2021 ACA reporting listed below.

What’s new for 2021?

The IRS released draft 2021 ACA information reporting forms along with instructions, which reflect two new codes to be used on Line 14 of Form 1095-C.

  • 1T: Individual coverage HRA offered to an employee and spouse with affordability determined using primary residence ZIP code.
  • 1U: Individual coverage HRA offered to employee and spouse using primary employment site ZIP code.

2021 ACA Reporting Deadlines

For 2021, ACA reporting deadlines have seemingly returned to normal. Around this time last year, the IRS announced in Notice 2020-76 that extended the January 31 deadline to furnish forms 1095-B and 1095-C to employees by 30 days. No extension has been announced for this year, at least not yet.

ACA Reporting Forms 2020 Tax Year Deadlines
(forms filed in 2021)
2021 Tax Year Deadlines
(forms filed in 2022)
1095-C due to employees (postmarked if mailed) March 2, 2021 March 2, 2022
1094-C and 1095-C due to IRS if paper filing February 28, 2021 February 28, 2022
1094-C and 1095-C due to IRS if electronic filing March 31, 2021 March 31, 2022

Potential Changes to Electronic-Filing Requirements

In July, the IRS proposed a new rule that would require more employers to electronically file tax forms – including Forms 1094-C and 1095-C. If the rule becomes effective, it would lower the electronic-filing threshold from 250 forms to 100 forms for 2022 and only 10 forms for 2023 and beyond. Follow the IRS for developments on this story.


IRS ACA Tax Provisions for Employers

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