New Jersey ACA Reporting Requirements: Filing 1095-C Data With The State

Last Updated: July 2026

New Jersey was one of the first states to build its own health coverage mandate after the federal penalty dropped to zero, and it comes with a reporting obligation that lands squarely on employers. The good news is that New Jersey doesn't ask for a brand-new form. It asks you to take the same 1095-C data you already prepare for the IRS and send it to the state through a separate channel, on a separate timeline.

The details are where it gets specific. New Jersey requires electronic filing only, expects you to proactively furnish forms to residents even if you use the federal upon-request option, and treats anyone who employs even one New Jersey resident as a filer, whether your business sits in Newark or Nebraska. If your organization has New Jersey staff, this guide walks through what the state expects: who must file, how the 1095-C-to-state process works, when it's due, and what the penalties look like.

Not in New Jersey.? Our State-Level ACA Reporting Guide covers all states with individual ACA mandates. 

Simplify New Jersey ACA Reporting

Table of Contents

Does New Jersey require state ACA reporting?

Yes. New Jersey enacted the Health Insurance Market Preservation Act in 2018, and its individual mandate took effect on January 1, 2019, the same year the federal penalty for going without coverage was reduced to zero. Under the law, most New Jersey residents must maintain minimum essential coverage (MEC) for themselves and their dependents, qualify for an exemption, or make a Shared Responsibility Payment on their state tax return.

To enforce that mandate, New Jersey requires every entity that provides minimum essential coverage to a New Jersey resident to report that coverage to the state. For employers, that means submitting your 1095 coverage data to the New Jersey Division of Taxation, separate from, and in addition to, your federal filing with the IRS. The state does not receive your federal forms from the IRS, so this is a genuinely separate obligation with its own system and its own deadline.

If you already handle federal ACA reporting, the lift is smaller than it sounds. New Jersey accepts the same IRS forms you're already generating. You're not building a new return; you're routing existing data to a second recipient.

If you are still confirming your federal obligation, start with our guide on which employers need to complete ACA filings. For the full picture of state mandates beyond New Jersey, see the State-Level ACA Reporting hub.

 

Who must comply with New Jersey ACA reporting?

New Jersey reporting applies to employers and coverage providers that offered minimum essential coverage to one or more New Jersey residents during the reporting year. Unlike the federal mandate, there is no 50-employee floor for the state filing obligation itself; the trigger is whether you cover a New Jersey resident, not how large you are. In practice, that means:

  • Applicable Large Employers (ALEs), generally those with 50 or more full-time and full-time-equivalent employees, that complete federal ACA reporting and cover at least one New Jersey resident. ALEs file Forms 1094-C and 1095-C.
  • Self-insured employers of any size that provided MEC to a New Jersey resident. These employers report the coverage themselves, since no carrier is doing it for them.
  • Insurance carriers and other MEC providers covering New Jersey residents, typically via Form 1095-B.

Residency, not payroll, is the trigger. The obligation isn't limited to businesses that withhold New Jersey payroll taxes. If you're an out-of-state employer with even one New Jersey resident on your plan, you're expected to file.

Part-year residents count. New Jersey treats someone as a resident for a month if they were domiciled in the state for at least 15 days that month.

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Not sure you are filing everything New Jersey requires?

Between federal 1094-C/1095-C filing, the separate state submission, carrier coordination, and the proactive furnishing rule, it's easy to have a gap you don't see until a resident's tax return flags it.

Our ACA Reporter handles federal and New Jersey state 1095-C filing from one dataset, so nothing falls through.

NJ 1095 Filing Requirements at a Glance

Here's where New Jersey's mechanics get specific. There are four things to get right: the form, the filing method, the furnishing rule, and the deadlines.

The form: your 1095-C data, with Part III completed

New Jersey accepts the NJ-1095, fully completed federal Forms 1095-A, 1095-B, and 1095-C, or 1095-C forms with Parts I and III completed. That last point is the one to watch. A 1095-C filed with only Parts I and II completed will not satisfy New Jersey.

The state relies on the coverage detail in Part III (the §6055 information showing who was actually enrolled and in which months) to verify that residents met the mandate. If your self-insured 1095-C forms don't carry Part III, they won't count for New Jersey purposes.

form 1095-C part 3

Electronic-Only Filing

New Jersey does not accept paper. All filing runs through the Division of Revenue and Enterprise Services (DORES). How you file depends on volume:

  • 50 or more forms: You must use the MFT SecureTransport (Axway) service. Files are submitted in bulk, the filename must start with "NJHIM", and each submission is capped at 12 MB. If you don't already have an Axway account, you request credentials from DORES before filing season.
  • Fewer than 50 forms: You may file using Form NJ-1095, which serves as a valid substitute for the 1095-B and 1095-C.

One more note: if you submit a correction file to the IRS, New Jersey requires you to submit that correction to the state as well.

 

The Deadline, the Latest of All the Mandates

The furnishing rule: New Jersey does not honor "upon request". This is the trap that catches employers who lean on the federal alternative furnishing method. Under the federal Paperwork Burden Reduction Act, employers can skip automatically mailing 1095-C forms and instead post a website notice letting employees request one. New Jersey does not follow this practice.

You must proactively send a 1095 form to each primary enrollee who is a New Jersey resident, regardless of whether a request is made. You do not, however, have to send separate forms to a resident's spouse or dependents; one form per primary enrollee is enough.

Typical deadlines for New Jersey

According to the New Jersey Division of Taxation, typical deadlines are as follows:

  • Furnish 1095 to New Jersey residents: March 2
  • File 1095 data with the NJ Division of Taxation: March 31

Note that New Jersey does not offer an automatic filing extension. If you need more time, you have to request it before the deadline. In a leap year, the furnishing date can shift by a day, so confirm each season.

 

The New Jersey Individual Mandate

The reason all of this reporting exists is the individual mandate itself. Since 2019, New Jersey has required residents to carry minimum essential coverage for each month of the year, qualify for an exemption, or pay the state's Shared Responsibility Payment (SRP) when they file their New Jersey return.

What is the New Jersey individual mandate?

Enacted under the Health Insurance Market Preservation Act and effective since 2019, when the federal penalty dropped to zero. It requires coverage for each month of the year, or a Shared Responsibility Payment (SRP) on the state return.

Who does the individual mandate apply to?

Most New Jersey residents of all ages, including children and part-year residents, unless they qualify for a specific exemption.

 

How residents satisfy and report it

Maintain minimum essential coverage (or a valid exemption) and report it on their New Jersey Resident Income Tax return (Form NJ-1040). Residents who go without coverage owe the SRP, which is based on income and family size and capped at New Jersey's statewide average annual premium for a bronze-level plan. For the 2025 tax year, an individual's SRP ranges from a minimum of $695 to a maximum of $4,908; families can owe more depending on household income and size.

 

New Jersey ACA Reporting Penalties

New Jersey's penalty picture has two distinct layers, and it's worth keeping them separate.

The individual mandate penalty (SRP). This is levied on residents, not employers, for going without coverage. It's assessed and collected in the same manner as New Jersey state income tax, using the income-and-family-size calculation described above and capped at the statewide average bronze plan premium. If federal premium tax credits ever become unavailable, the state has said the SRP will not be enforced for that tax year.

Employer filing penalties. New Jersey's public guidance for employers does not post a specific fine for late or missed filings. The statute builds on the federal information-return penalty framework, and some filing vendors cite a figure of roughly $50 per return on that basis, but the Division of Taxation has not published its own penalty schedule. Either way, the absence of a headline number is not grounds for treating the deadline as optional. The bigger exposures for employers are practical:

  • You inherit the carrier's failure. For fully insured plans, if your carrier doesn't file for your New Jersey residents, the obligation falls back on you.
  • Bad or missing data creates employee problems. Incomplete Part III data or a missed furnishing deadline can leave residents unable to substantiate coverage, generating disputes that route straight back to HR.
  • Rules can change. New Jersey has signaled it may define employer penalties in the future. Building a compliant, repeatable process now is cheaper than reacting later.

Treat the March deadlines as firm, keep documentation, and confirm current specifications with the Division of Taxation each season.

 

Your NJ ACA State Filing Checklist

Use this as a working checklist heading into filing season:

    • Identify your New Jersey residents. Include part-year residents (domiciled 15+ days in any month) and remote employees, not just people who work at a New Jersey site.
    • Confirm your plan type.
      • Fully insured? Verify in writing that your carrier is filing and furnishing for New Jersey residents.
      • Self-insured? The filing is yours.
    • Check your forms carry Part III. Make sure self-insured 1095-C forms are completed through Part III, not just Parts I and II.
    • Set up your filing channel.
      • Filing 50+ forms? Confirm your MFT SecureTransport (Axway) credentials and that your file name starts with "NJHIM".
      • Under 50? Prepare the NJ-1095.
    • Furnish proactively. Send a 1095 to every New Jersey primary enrollee by March 2, even if you use the federal upon-request method elsewhere.
    • File with the state by March 31. Remember, there's no automatic extension.
    • Mirror any IRS corrections to the state. If you correct with the IRS, correct with New Jersey, too.
    • Keep records. Retain proof of coverage offers, enrollment months, furnishing, and submission confirmations.

 

aca state filing nj compliance checklist

Frequently Asked Questions

Not necessarily. New Jersey accepts your federal 1095-C (with Parts I and III completed), as well as the 1095-A and 1095-B. Employers filing fewer than 50 forms may use the NJ-1095 as a substitute. The key requirement is that the coverage detail in Part III is present.

No. New Jersey requires you to proactively send a 1095 to each New Jersey resident primary enrollee, regardless of whether they request it. The federal notice-and-request approach does not satisfy the state.

Yes, if you employ or cover even one New Jersey resident. The obligation follows the resident, not your business address or your payroll tax withholding.

As a general rule, New Jersey uses the same two dates every year: furnish 1095 forms to New Jersey residents in early March, and file your 1095 data with the New Jersey Division of Taxation by March 31.

The furnishing deadline tracks the federal rule of 30 days after January 31, which falls on March 2 for the 2025 tax year; it can shift by a day or two when that date falls on a weekend, so confirm it each season. The March 31 filing deadline is fixed. For the 2025 tax year, the dates are March 2, 2026, and March 31, 2026. New Jersey does not offer an automatic filing extension, so if you need more time, you must request it before the deadline.

Typically your insurance carrier files the 1095-B for enrolled New Jersey residents. But you remain responsible if the carrier doesn't, so confirm it's being done rather than assuming.

The Shared Responsibility Payment is based on income and family size and is capped at New Jersey's statewide average annual premium for a bronze-level plan. For the 2025 tax year, it runs from a minimum of $695 to a maximum of $4,908 for a single individual, and higher for families. It's paid by the resident, not the employer.

Simplify New Jersey ACA Reporting With ACA Reporter

New Jersey's requirements aren't complicated so much as easy to get partially right, the missed Part III data, the carrier you assumed was filing, the residents you furnished "upon request" when the state expected a mailed form. Each gap is small on its own and each one surfaces at the worst time: on an employee's tax return.

ACA Reporter from Points North generates your 1095-C data once and files it where it needs to go, both to the IRS and to the New Jersey Division of Taxation, with Part III coverage detail intact and the state's electronic submission handled for you. Instead of tracking separate systems and separate deadlines, you work from a single source of truth and confirm your New Jersey filing is complete rather than hoping it is.

If you are ready to take New Jersey compliance off your plate, request a demo.