Two Sets of ACA Reporting Requirements: Employer and Individual Mandate

Two Sets of ACA Reporting Requirements: Employer and Individual Mandate

Final Instructions for IRS Reporting on Individual and Employer Mandates

We have previously published two blog articles on the detailed and somewhat complex ACA reporting requirements for Employer Mandate and Individual Mandate. Please feel free to revisit those articles as they contain valuable links to the necessary draft IRS forms, reporting instructions, fact sheets and more:



Necessary Forms and Instructions for IRS Reporting

Insurers and employers have two (2) forms they must provide the IRS.

  • Each must provide a form that serves as a cover letter as well as forms providing data on the individual or employer mandate. The forms are to be completed and filed as follows:
    • Employers will file Form 1094-C (a transmittal/cover sheet) to the IRS only,
    • And Form 1095-C to both the IRS and named individuals. If its plan is insured, the employer will only complete Parts I and II of Form 1095-C.
    • Insurers will send Form 1094-B (a transmittal/cover sheet) to the IRS only,
    • And Form 1095-B to both the IRS and named individuals for insured coverage only.

FORM 1094C FORM 1095C FORM 1094B FORM 1095B

Fact Sheet: ACA Individual and Employer Mandate Reporting Requirements

CignaThe fact sheet is provided by our partner Cigna and contains the following valuable information:

  • Reporting Basics
  • Large Employer Reporting – Employer Mandate
    • Data to Report
    • Reporting Penalties
  • Minimum Essential Coverage (MEC) Reporting – Individual Mandate
    • Data to Report
    • Reporting Penalties

We encourage you and your HR team to download the Cigna ACA Fact Sheet below:

ACA Reporting Reqs Fact Sheet (Employer/Individual Mandate)




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