The IRS issued draft instructions related to ACA reporting requirements for 2023 (2023 Draft Instructions for Forms 1095/1094-C and 1095/1094-B).
Here are the changes and deadlines employers need to be aware of:
In March 2023, new IRS rules required that all ALEs and most smaller employers file forms electronically and can no longer file paper forms.
According to the draft instructions, starting in Q1 2024 for the 2023 tax year, 1095/1094-C and B forms must be filed electronically for all employers who file 10 or more of various types of information returns, including W-2s, 1099s, 1098s, and 1095-B or C.
Thus, most employers will file electronically and can no longer file via paper (the threshold was 250).
The deadlines for filing ACA reports with the IRS will remain the same in 2024. As a reminder, paper filings are due to the IRS by February 28, 2024, and electronic filings are due as of April 1, 2024 (March 31st is a Sunday). Filers can apply for an extension with the IRS by submitting Form 8809 prior to the filing due date.