The Complete Checklist for State-Level ACA Reporting Mandates

Meeting your federal ACA e-filing obligations doesn’t guarantee total compliance. California, New Jersey, Rhode Island, and Washington D.C. enforce their own Individual Mandates based strictly on employee residence — meaning just one remote worker in a mandated state triggers reporting requirements for your organization. 

While fully insured employers can sometimes rely on carriers for state-level submissions, self-insured organizations – and all employers with residents in Washington D.C. – bear the full responsibility of filing this data themselves. As the 2026 filing season accelerates, use this checklist to verify your state-level ACA reporting readiness and ensure you hit every localized deadline.

California ACA Reporting Mandate

California requires organizations to report employee insurance information to the California Franchise Tax Board (FTB) annually.

• The Requirement: Organizations that employ California residents must file, regardless of whether the organization is located in or out of the state.
• The Format: Information should be submitted using federal Forms 1094-C, 1095-C, and 1095-B. The FTB has aligned with the IRS’s lowered threshold, strictly requiring electronic filing if you are submitting 10 or more information returns. Paper filing is essentially obsolete.
• The Penalty: Employers that fail to meet California reporting requirements face a penalty of $50 per individual not reported on.
• The Deadline: The official FTB state electronic filing deadline is March 31. California does offer an automatic, penalty-free extension allowing employers to electronically file by May 31 (effectively June 1, 2026).

New Jersey ACA Reporting Mandate

New Jersey’s health insurance mandate requires employers to verify coverage for residents to ensure they maintain minimum essential coverage.

• The Requirement: Organizations must transmit health coverage data for any New Jersey resident employed during the tax year.
• The Format: Files must be submitted electronically to the New Jersey Division of Taxation using the state’s MFT SecureTransport (Axway) service. Paper filing is not available. The state accepts NJ-1095 forms or fully completed federal 1095-B/C forms.
• The Penalty: While New Jersey has not yet explicitly outlined financial penalties for non-compliant employers, organizations must still adhere to the mandate to avoid fines or audits.
• The Deadline: The state filing submission is due on March 31, 2026.

Rhode Island ACA Reporting Mandate

Rhode Island’s mandate mirrors the federal reporting structure but requires a direct electronic transmission to the state government.

• The Requirement: Employers must report healthcare information for any Rhode Island residents they employ.
• The Format: Employers submit their federal Forms 1094 and 1095-B/C electronically to the Rhode Island Division of Taxation.
• The Penalty: Like New Jersey, the state currently has not established explicit employer penalty structures, but compliance remains mandatory.
• The Deadline: The state electronic filing submission is due on March 31, 2026.

Massachusetts ACA Reporting Mandate

Massachusetts was a pioneer in healthcare mandates (often referred to as “Romneycare”), and its reporting requirements remain strictly enforced using state-specific forms. (Note: Trusaic does not support Massachusetts filing).

• The Requirement: Employers with operations in Massachusetts must submit healthcare information regarding Minimum Creditable Coverage (MCC) to the Department of Revenue (DOR).
• The Format: Unlike other states that accept federal 1095-C data, Massachusetts requires employers (or their insurance carriers) to electronically file Form MA 1099-HC through the MassTaxConnect portal.
• The Penalty: Failure to fulfill state filing requirements results in a $50 penalty for every individual not reported on, up to a maximum penalty of $50,000.
• The Deadline: The actual electronic filing submission to the state via MassTaxConnect is due March 31, 2026.

Washington D.C. ACA Reporting Mandate

Note: D.C. operates on a slightly later timeline than the March 31 rush, but preparation must happen concurrently.

• The Requirement: Applicable Large Employers (ALEs) must file reports if they employ D.C. residents, regardless of whether they actually withhold D.C. payroll taxes or whether the employee actually enrolled in the offered coverage..
• The Format: Employers must electronically file Forms 1094 and 1095-B/C with the D.C. Office of Tax and Revenue (OTR) via the MyTax.DC.gov portal. Paper filing is not accepted under any circumstances.
• The Penalty: While there are no stated reporting penalties for employers, non-compliant taxpayers face a stiff individual mandate penalty. For the 2025 tax year, the D.C. penalty is the greater of two amounts: a flat fee of $795 per adult ($397.50 per child) or 2.5% of household income over the federal tax filing threshold.
• The Deadline: The state electronic filing submission is due on April 30, 2026.
  Note: While D.C. accepts the federal furnish-on-demand method (posting an online notice), your furnishing obligations remain. You must still provide physical forms to employees upon request and electronically file all data with the D.C. OTR.

The Multi-State Formatting Challenge

A critical detail that trips up many employers is the data formatting itself. State revenue departments do not accept standard IRS AIR XML files. 

Your federal data must be meticulously mapped and converted into the unique file formats, XML schemas, and specifications required by each distinct state portal. 

Attempting to submit an unmodified federal file to a state agency will result in a rejection.

Streamlining Your State Filing Strategy with Trusaic

Navigating state-specific XML schemas on top of your federal reporting is a massive drain on your team’s resources. Trusaic’s ACA State Filing solution completely eliminates this administrative burden by handling the heavy technical lifting for you. 

We automatically map and convert your existing federal data into the unique, highly specific file formats required by California, New Jersey, Rhode Island, and Washington D.C. (Note: we do not handle filings for Massachusetts). 

By managing the secure transmission directly to each respective state agency, we ensure your data is accepted on the very first attempt — saving hours of manual formatting and protecting your organization from localized penalty risks.