The IRS has announced that the Affordable Care Act Information Returns (AIR) system — the platform used for electronic transmission of ACA Forms 1094-C and 1095-C — will undergo its annual maintenance shutdown from Dec. 7, 2025, through Jan. 8, 2026.
During this time, employers, vendors, and payroll/HCM systems will not be able to file ACA information returns electronically. While the outage occurs every year, the timing is critical: many organizations are already preparing for the March 31, 2026 federal electronic filing deadline.
If your organization handles ACA reporting internally or depends on a third-party system, now is the time to plan ahead to avoid delays once AIR reopens.
What This Shutdown Means
The IRS AIR system going offline affects only one thing: you cannot electronically submit ACA Forms 1094-C/1095-C during the outage window.
Key points:
- You can still prepare your filings during this time.
- You can still test scenarios and validate data internally.
- But you cannot transmit any ACA filings to the IRS until the system reopens Jan. 9, 2026.
For organizations that typically rush to file early in Q1 — or those that experience rejections and need time to resubmit — this blackout can compress an already tight timeline.
Why This Matters for Employers
Even with the AIR system temporarily shut down, ACA compliance timelines do not change. Employers still must:
- Furnish employee Forms 1095-C by March 2, 2026 (if following the standard deadline, unless the new federal “furnish upon request” rule applies to your organization).
- File electronically by March 31, 2026.
Because the system reopens Jan. 9, this leaves fewer than 12 weeks to finalize, validate, correct, and file 1094-C and 1095-C forms to the IRS.
For large employers or organizations with complex ACA data such as multiple EINs, variable-hour workforces, shifting eligibility, or seasonal staffing, this compressed window increases the risk of:
- Data mismatches
- Code errors
- Missing coverage months
- Failed affordability calculations
- IRS rejections with little time to correct
How to Prepare During the AIR Outage
Employers should use the AIR shutdown period to get ahead of their 2026 ACA reporting:
1. Validate and clean data before January
The majority of ACA penalties stem from incorrect or incomplete data. Evaluate:
- Full-time status determinations
- Affordability calculations
- Employee and dependent demographic accuracy
- Missing or contradictory Line 14/16 codes
- Gaps in coverage reporting
2. Run a Penalty Risk Assessment early
This determines whether your data is likely to trigger:
- 4980H(a) penalties (failure to offer coverage to 95% of full-time employees)
- 4980H(b) penalties (failure to offer affordable coverage)
Identifying issues now ensures they can be corrected before filing season begins.
3. Begin preparing employee forms
Even though you cannot file during the outage, you can still:
- Generate draft employee 1095-C forms
- Conduct internal reviews
- Address errors from prior years
4. Ensure your team understands the timeline
With AIR reopening Jan. 9, organizations have a narrow window to:
- Finalize 1095-C forms
- Complete internal approvals
- Submit filings
- Respond quickly if the IRS rejects any transmissions
How Trusaic Helps You Stay Ahead of the 2026 Filing Season
Trusaic’s ACA Compliance Solutions ensure you are fully prepared long before filing season begins. We help you:
- Automate all ACA calculations, including affordability and eligibility
- Validate your data in real time to prevent rejected filings
- Run comprehensive Penalty Risk Assessments to identify issues early
- Leverage certified integrations with platforms like Workday and UKG Ready
- Guarantee audit readiness with complete, accurate, and defensible reporting
- File electronically on your behalf as soon as AIR reopens
The AIR system shutdown is temporary but the need for accurate, timely ACA reporting is not. Preparing now ensures you avoid filing delays and prevent costly mistakes during the 2026 reporting season.
Schedule a demo today and secure your filing readiness ahead of the March 31, 2026 deadline.