ACA state reporting
requirements 2024

ACA State Reporting
Requirements 2024

What is ACA state reporting?

Each year, organizations must prepare their 1094-C and 1095-C filings with the IRS. Some employers must also file their ACA information with individual state governments as well, adding complexity to the annual reporting requirements. Below we identify the states that require additional ACA reporting, explain how these filing obligations came about, and discuss how organizations can reduce their risk by partnering with an expert in ACA compliance.

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History of state ACA reporting

First introduced in 2010, the ACA among many things, encourages U.S. residents to obtain health insurance, and for employers to provide it. When the law was first passed, it consisted of two main parts:

  • The Employer Mandate: Applicable Large Employers (ALEs), or employers with 50 or more full-time employees and full-time equivalent employees, must offer Minimum Essential Coverage (MEC) to at least 95% of their full-time workforce and their dependents
  • The Individual Mandate: All U.S. residents were required to obtain health insurance or pay a penalty

Legislation enacted in 2017 changed how the ACA operates. That year, Congress passed The Tax Cuts and Jobs Act, which zeroed out the federal individual mandate, effectively eliminating it. Penalties for failing to obtain qualifying insurance were officially phased out in 2019. Since then, several states, as well as the District of Columbia, have responded by implementing individual mandates of their own.

State individual mandates:
how they affect employers

What does this mean for organizations that employ residents in states with individual mandates? It means they must file a report on their employees' health coverage to the state government, in addition to filing the annual 1094-C and 1095-C reports with the IRS. As a function of these additional state requirements, ALEs must also furnish copies of 1095-C forms to their employees.

Note that an organization's location doesn't affect whether it's obligated to comply with a state individual mandate and subsequent state reporting obligations. The deciding factor is where the employees live. So this adds an extra layer of complexity for employers that have remote workers in different states.

If your organization has just one employee filing taxes in a state that mandates ACA state reporting, the requirements apply. You must file a report in accordance with that state's laws.

Are you one of the employers bestowed with extra paperwork to file with state agencies each year? Let's find out. Below, you'll find a chart of all states that have passed individual mandates, plus several with requirements forthcoming.

NOTE: You may find differences in the ACA state reporting requirements of previous years. Since certain states are still rolling out changes, it's worth checking twice to ensure your organization is compliant.

California IRS 1094 and 1095-B/C Employer Distribution:
January 31, 2024
State Filing:
April 01, 2024
District of Columbia IRS 1094 and 1095-B/C Employer Distribution:
March 01, 2024
State Filing:
April 30, 2024
Massachusetts MA 1099-HC Employer Distribution:
January 31, 2024
State Filing:
January 31, 2024
New Jersey NJ-1095, 1095-A, 1095-B/C Employer Distribution:
March 01, 2024
State Filing:
April 01, 2024
Rhode Island IRS 1094 and 1095-B/C Employer Distribution:
March 01, 2024
State Filing:
April 01, 2024


California's individual mandate was signed into law on July 2, 2019. It stands in place of the now-defunct federal individual mandate. It took effect on January 1, 2020.

California's state individual mandate law requires its residents to have MEC for a minimum of nine months out of the year. Individuals who fail to meet this requirement must pay a fine, unless they qualify for an exemption. For the 2024 tax year, the penalty could be as high as $1,961 per adult and $900 per dependent.

The mandate also includes California ACA reporting requirements for employers. Organizations must submit an annual report to show their employees (and their dependents) had MEC for a minimum of nine months during the year. Find details about reporting requirements for employers below:

California employer reporting requirements

The purpose of California ACA reporting is to ensure that state residents comply with the obligation to obtain MEC. It also allows the California Franchise Tax Board (FTB) to determine whether an employer offered the amount of coverage required by law.

Here's what employers of California residents need to know:

  • Organizations who employ California residents must file, regardless of whether the organization is located in or out of state
  • Employers must report employee insurance information with the California Franchise Tax Board (FTB) once per year
  • Information should be submitted to the state using federal Forms 1094-C, 1095-C, and 1095-B. Organizations must also distribute copies to employees.
  • You should not submit forms for employees who were offered coverage but did not enroll
  • If your organization offers full insurance plans, the insurance company may report information to the state about each individual enrolled in coverage. If the insurer fails to do this, employers can be held responsible and fined.
  • You can file electronically or by mail. The FTB encourages electronic filing. If you are filing more than 250 forms of a certain type, you must file electronically. For example, if you have 500 Forms 1095-C and 75 Forms 1095-B, you do not need to file Forms 1095-B electronically.

California ACA reporting deadlines in 2024

If your organization has a California state ACA reporting obligation, pay attention to these 2024 deadlines, reflective of the 2023 tax year:

January 31, 2024

Employers must provide health insurance information (Form 1095-B/C) to current employees and former employees covered in the prior year

April 01, 2024

This is the deadline for California ACA state filing. Whether you file via mail or electronically, you must submit all forms to the FTB before this date.

Penalties for non-compliance

Employers who fail to meet the California ACA reporting requirements may be fined $50 per individual not reported on.

District of Columbia

The District of Columbia (D.C.) signed an individual insurance coverage mandate into law on June 26, 2018. The D.C. mandate requires local residents to obtain and hold qualifying coverage throughout the year.

The mandate went into effect on January 1, 2019. The D.C. ACA reporting requirements were officially released on August 9, 2019.

D.C. employer reporting requirements

D.C.'s individual mandate law includes reporting requirements for employers. We've outlined the specifics of D.C.'s ACA reporting requirements below:

  • Any organization that provides MEC to at least one D.C. resident (and their dependents) must report this information to the state government
  • Specifically, organizations must file all forms with the D.C. Office of Tax and Revenue (OTR), once per year
  • The law also requires employers to make this coverage information available (via copies of Form 1095-B/C) to insured employees
  • Only Applicable Large Employers (ALEs) are required to file reports. The law applies to any ALEs who employ D.C. residents, regardless of whether they withhold D.C. payroll taxes
  • Fully insured employers are subject to D.C. ACA reporting requirements
  • Employers must electronically file Forms 1094 and 1095-B / 1095-C with the D.C. OTR. Paper filing is not accepted.

D.C. ACA reporting deadlines in 2024

If your organization has a D.C. ACA reporting obligation, pay attention to these 2024 deadlines, reflective of the 2023 tax year:

March 01, 2024

Organizations must furnish copies of Form 1095-B/C to employees with D.C. residency by this date

April 30, 2024

The deadline to file ACA information with the District is April 30.

Penalties for non-compliance

At this time, the D.C. OTR hasn't published information about penalties for non-compliant employers. However, there is a known penalty in place for individual taxpayers. Individuals who fail to obtain qualifying insurance may be fined 2.5% of their salary, or $700.


Since 2006, the Massachusetts Health Reform Law has required Massachusetts residents over the age of 18 to have Minimum Creditable Coverage (MCC). MCC refers to a minimum level of insurance benefits. Taxpayers who fail to acquire insurance may be subject to fines.

Also known as "Romneycare", the law aims to ensure adequate healthcare coverage for all Massachusetts residents. Since it predates the ACA, it remained unchanged when the ACA federal individual mandate was eliminated.

Massachusetts employer reporting requirements

Massachusetts ACA reporting requirements, or the Massachusetts Health Reform Law requirements are slightly different from those of other states. Here's what employers of Massachusetts residents need to know:

  • Unlike other states, Massachusetts requires employers to file a state-specific form called Form MA 1099-HC. This form indicates whether an individual meets the state's requirement for Minimum Creditable Coverage (MCC).
  • Employers must submit Form MA 1099-HC online through the MassTaxConnect portal. They must provide copies for employees with Massachusetts residency.
  • Most insurance carriers that provide full insurance plans will submit forms MA 1099-HC on behalf of employers. However, should a carrier fail to do so, the government will hold employers responsible and may levy fines for non-compliance.
  • In addition, employers with 6 or more employees must file the Health Insurance Responsibility Disclosure (HIRD) Form once per year (electronically, via the MassTaxConnect portal)
  • This includes out-of-state employers who have at least six employees in Massachusetts

Massachusetts ACA reporting deadlines in 2024

If your organization has a Massachusetts state ACA reporting obligation, pay attention to these 2024 deadlines, reflective of the 2023 tax year:

January 31, 2024

By this date, employers must furnish copies of MA 1099-HC to employees

January 31, 2024

This is the deadline by which employers should file Form MA 1099-HC electronically through the MassTaxConnect portal

Penalties for non-compliance

Massachusetts levies fines of $50 per individual for employers that do not fulfill ACA state filing requirements. The maximum penalty is $50,000.

New Jersey

New Jersey passed an individual mandate law that includes requirements for employers. Signed into law on May 30, 2018, this mandate took effect on January 1, 2019.

New Jersey has state ACA reporting stipulations that employers must adhere to in addition to the federal ACA requirement to furnish Forms 1095-C to employees and file with the IRS.

If your organization employs New Jersey residents, pay close attention to the New Jersey ACA reporting requirements below.

New Jersey employer reporting requirements

  • Any organization that employs New Jersey residents must comply with New Jersey ACA reporting requirements, regardless of the number of employees. (Federal ACA law only requires employers with 50 or more employees to report health insurance information).
  • Employers that provide full insurance do not need to file a state-level report if the insurance carrier has already done so
  • Employers that participate in a multi-employer plan can avoid New Jersey ACA reporting as long as the plan sponsor files the report
  • The requirements apply to all organizations that employ New Jersey residents, regardless of whether they are located in or out of New Jersey state
  • The reporting obligation applies even if the employer does not withhold New Jersey payroll taxes
  • The forms acceptable to the government of New Jersey are NJ-1095 forms, fully completed federal 1095-A, 1095-B, and 1095-C forms, and/or 1095-C forms with parts I and III completed
  • Employers must submit all forms electronically through the MFT SecureTransport (Axway) service. Paper filing isn't available.

New Jersey ACA reporting deadlines in 2024

Does your organization employ New Jersey residents? If so, don't miss these important 2024 dates, reflective of the 2023 tax year:

March 1, 2024

Employers must furnish a 1095 form to each New Jersey resident employee to whom they provided minimum essential coverage in all or part of 2023

April 1, 2024

Employers must send 1095 health coverage forms to the New Jersey Division of Taxation by this date

Penalties for non-compliance

New Jersey has not yet stated what penalties it may impose on non-compliant employers. But it's important for organizations to adhere to New Jersey ACA reporting requirements in order to avoid any surprise fines. We'll update you with more information as soon as it's available.

Rhode Island

In 2017, the ACA federal individual mandate was repealed, with penalties eliminated in 2019. This prompted the state of Rhode Island to pass its own individual mandate on July 5, 2019. This law took effect January 1, 2020.

In addition to requiring individuals to have "qualifying health coverage", Rhode Island's mandate includes reporting obligations for employers. They must inform the state government about coverage they provide to Rhode Island residents they employ. This allows the state to track compliance with the state's requirements to obtain healthcare.

Rhode Island employer reporting requirements

Rhode Island ACA state reporting requirements to be met in 2024 are as follows:

  • Any employer that provided coverage for Rhode Island residents for any months during 2023 must submit a state-level report
  • Organizations must file all Rhode Island ACA reporting forms through the state's Division of Taxation website
  • The acceptable forms to submit to the Division of Taxation are: federal forms 1094-C / 1095-C
  • Employers must also provide Form 1095-B to their employees
  • These requirements are in addition to federal ACA reporting
  • For employers that provide full insurance: if the insurance carrier already files state reporting, the employer isn't obligated to do so

Rhode Island ACA reporting deadlines in 2024

The Rhode Island ACA reporting deadlines were extended last year. Previously, the filing deadline for submitting 1095-C forms to the Rhode Island Department of Taxation was January 31.

These are the 2023 deadlines to be met in 2024

March 01, 2024

By this date, employers must provide copies of Form 1095-B/C to all employees (of former employees) who had insurance coverage in 2023

March 31, 2024

This is the deadline for employers to fulfill their Rhode Island ACA reporting obligation. They must submit federal forms 1095-B/C to the Rhode Island state government.

Note: These deadlines are permanent. Employers can expect the dates to stay the same each year. Rhode Island's Department of Taxation has stated that the deadline changes were made so that they align with the IRS' permanent ACA filing deadline.

Penalties for non-compliance

At this time, it's unclear whether Rhode Island will impose fines on organizations that fail to file state ACA reports. We suggest subscribing to the ACA Times for ACA state reporting information and updates.

Managing state ACA reporting requirements

If you've read this far, you've probably noticed that ACA state reporting requirements are complex. Keeping up with all the different regulations and reporting requirements can be a challenge for organizations.

Also, individual mandates are recent or forthcoming in many states. Changes are being made constantly, throwing organizations for a loop. Don't be caught off guard. Keep reading to find out how to streamline your ACA state and federal filing process.

How to simplify ACA state and federal filing

How can employers collect the required information, process it, and send it on time? Those who employ residents of states with Individual Mandates are obligated to provide accurate, complete data not only to the federal government but to the state as well.

Then there's the issue of missing or disparate data. Data errors aren't just a compliance problem. They're a driver for penalties in many states. Some states are already handing down hefty fines to organizations that aren't aware of their reporting obligations.

The solution? A combination of automated software and legal expertise can help organizations ensure compliance with regulations to eliminate the risk of penalties. Fortunately, Trusaic offers comprehensive ACA reporting solutions that include:

  • Advanced software technology for optimizing data management
  • Designated ACA specialists to manage compliance and risk mitigation
  • Expert assistance for organizations facing IRS audits

ACA Complete®: Your comprehensive federal and state ACA reporting solution

With ACA Complete, you can make your ACA reporting burden featherlight. The elite full-service compliance solution includes reporting management, seamless data integration for complete visibility, and IRS audit defense. ACA Enterprise enables your organization to offload its state and federal ACA responsibilities.

For organizations that only need assistance with ACA state reporting, we offer a stand-alone ACA state filing solution. Find the right package for your organization's unique needs on our reporting assistance page.

Achieve compliance (and peace of mind) the simple way with our ACA compliance solutions. We invite you to schedule a demo at a time that works best for you. We'll explain how our services and software make ACA compliance easy, and answer any questions you may have. You can also find more information about our ACA filing assistance products below.

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ACA state reporting?