Important Change to Form 1095 Electronic Reporting


Beginning in 2024, most employers will need to file their Affordable Care Act (ACA) forms electronically.  For information returns required to be filed on or after January 1, 2024, the electronic-filing threshold has been decreased to 10 or more Forms 1095-C.  Previously, only employers filing 250 or more returns were required to file electronically.

The IRS has established the Affordable Care Act Information Returns System (the AIR System) for online filing of ACA forms.  An individual filing ACA forms electronically on behalf of the employer must obtain an account and apply for a Transmitter Control Code.  Employers newly subject to electronic reporting in 2024 should discuss the requirements with their payroll vendor or gain access to the AIR System as soon as possible.  Additional information about the AIR System is available at

Note: Small employers (those not subject to the employer shared-responsibility provisions) with self-funded health plans will file Form 1095-B with employees and the IRS to report individuals who are covered by minimum essential coverage.

If you have questions on the new electronic filing requirement under the ACA, call ASR Health Benefits at (616) 957-1751 or (800) 968-2449.