2020 ACA Reporting Deadlines

October 22, 2020|

Applicable large employers (ALEs), employers with 50 or more full-time and full-time equivalent employees, are required to annually report to their employees and the Internal Revenue System (IRS) health insurance coverage offered to their eligible employees. Form 1095-C is sent to employees and Form 1094-C is sent to the IRS along with copies of all 1095-C forms. Small employers with self-funded insurance plans use Forms 1095-B and 1094-B instead.

On Oct. 2, 2020, the IRS announced in Notice 2020-76 that it will extend the January 31 deadline to furnish forms 1095-B and 1095-C to employees by 30 days. The current deadlines for 2020 reporting are provided below.

Original Deadline Extended Deadline
Form 1095-B (to employees) January 31, 2021 March 2, 2021
Form 1095-C (to employees) January 31, 2021 March 2, 2021


The Notice does not extend the deadline for filing forms (including Forms 1094-B, 1095-B, 1094-C, or 1095-C) with the IRS. The dates for 2020 reporting, submitted in 2021, appear below, along with last year’s deadlines for reference.

ACA Reporting Forms 2019 Tax Year Deadlines
(forms filed in 2020)
2020 Tax Year Deadlines
(forms filed in 2021)
1095-C due to employees (postmarked if mailed) March 2, 2020 January 31, 2021 (extended to March 2, 2021)
1094-C and 1095-C due to IRS if paper filing February 28, 2020 February 28, 2021
1094-C and 1095-C due to IRS if electronic filing March 31, 2020 March 31, 2021


Additionally, while the date for filing forms with the IRS was not automatically extended, employers may still seek a 30-day extension by submitting Form 8809 by the filing due date.

For more information, visit the Internal Revenue Service’s (IRS) ACA resource page for employers.

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