2023 ACA Reporting Deadlines, Forms and Instructions

October 18, 2023

Employers should take note of the following changes and dates for 2023 ACA Report filing.

At A Glance

The IRS published the deadlines for 2023 ACA reporting. Take note of these important dates and guidelines:

  • Deadline to Furnish to Individuals: March 1, 2024
  • Deadline to File Electronically with IRS: March 31, 2024
  • Deadline to File Paper Statements with IRS: February 28, 2024
  • Threshold for Mandatory Electronic Filing: 10 Information Returns

Deadlines to Furnish and File 1095-C

2023 marks the first filing year with the permanent automatic extension of time for providers to furnish the 1095-C form to individuals. Employers subject to the ACA employer shared responsibility mandate must furnish a completed 2023 Form 1095-C to employees no later than March 1, 2024. Due to the permanent extension to furnish, no additional extensions will be granted.

Per the recently published 2023 1095-C instructions, employers who file information returns electronically to the IRS must file the 2023 Forms 1094 and 1095 by March 31, 2024. If filing paper forms, the deadline for the 2023 forms is February 28, 2024. No other significant changes were announced in the instructions.

Final forms 1094-C and 1095-C were also released by the IRS and contain no significant changes. It is important to note that these deadlines do not apply to state-specific health care reporting requirements.

New Threshold for Mandatory Electronic Filing

The 2023 filing season will be the first year with the lower mandatory filing threshold. Previously, electronic filing was mandatory for those filing 250 or more information returns. Effective with returns filed in 2024, electronic filing is required for those required to file 10 or more information returns.

Reminder: “Good-Faith Relief” Expired

For years, employers were able to rely on “good-faith relief” to potentially avoid IRS tax penalties for non-compliance. This relief allowed employers who reported incomplete or incorrect information on their information returns to show they made a good-faith effort to file and furnish. This relief expired in 2021 and is no longer available.

Learn More: ACA Compliance Guide for Employers

Next Steps

Paylocity clients must finalize ACA form data by the end of business on 01/02/2024 to ensure all Company Administrators receive year-end forms timely.

Clients may enroll in ACA reporting through November 1, 2023 for the current tax year. Additional resources for Paylocity clients can be found here.

Paylocity clients may also consider the following alternative options to allow extra time to finalize forms and avoid reprint fees:

  • Go Paperless to avoid reprint fees of $100.00 per package plus delivery, and make updates to original forms until end of business February 15, 2024.
  • Packages include any quantity of forms in the same request (1 form, multiple forms, or all forms)

Thank you for choosing Paylocity as your Payroll Tax and HCM partner. This information is provided as a courtesy, may change and is not intended as legal or tax guidance. Employers with questions or concerns outside the scope of a Payroll Service Provider are encouraged to seek the advice of a qualified CPA, Tax Attorney or Advisor.

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