Sarah Borders, CEBS October 2, 2023 5 min read

Draft 1095/1094-B & C Forms for 2023 Issued

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.


Sarah Borders, CEBS

Principal, Benefits Compliance Solutions. Sarah has spent the last 15 years in the employee benefits industry, has numerous designations and serves on NAHU’s Employer Working Group Subcommittee and is an active board member of Austin AHU. She recently stepped down as Vice President of Benefits Compliance at one of the nation's largest brokerage firms to start her own compliance consulting practice. Her designations include an active license with the Texas Department of Insurance, CEBS (Certified Employee Benefits Specialist), Certified Health Care Reform Professional, HIPAA certification and Health Care Service Associate. She holds an MBA from Texas A&M Corpus Christi and a BA from University of Incarnate Word. Her consulting firm, Benefits Compliance Solutions, partners with employers to identify unknown risks and avoid hundreds of thousands of dollars in fines and lawsuits from failure to comply with their healthplan obligations.