Last Updated: October, 2026
ACA reporting season can feel far away when you have a full plate, but the work that makes January through April go smoothly happens earlier. Reviewing your systems and data in the fourth quarter gives you time to fix issues before deadlines arrive, instead of finding them during filing.
Review Your Safe Harbors and Measurement Periods
Safe harbors and measurement periods are some of the most nuanced parts of ACA compliance, even for experienced teams. Whether you use the W-2, rate of pay, or federal poverty line safe harbor, now is a good time to confirm your affordability calculations are accurate and documentation is complete.
Review your measurement periods the same way. Confirm that your look-back and stability periods still fit your workforce. Changes to these periods generally can't be made mid-cycle without creating some compliance risk, so plan any adjustments ahead of the next period.
Check the Accuracy of Your Payroll Data
Inaccurate payroll data is one of the most common sources of ACA reporting errors. Your 2027 filings depend on data collected through 2026, including employee classifications, hours worked, offer of coverage codes, and coverage start and end dates.
Give some extra attention to variable-hour employees, seasonal workers, and anyone whose status changed during the year. Also, confirm that your payroll, HRIS, and benefits systems share data consistently. When those systems don't align, discrepancies tend to surface on Forms 1095-C.
The Dates You Absolutely Cannot Miss
These deadlines apply to the 2027 coverage year.
January 31, 2027 (Sunday)
- California's Form 1095 distribution deadline (state requirement). Because the date falls on a weekend, plan to mail by Friday, January 29.
- State filing for Massachusetts
- If you are not planning to distribute 1095 forms to employees, notice must be posted by this date. The notice must be clear and obvious and include how an employee can request a copy of their 1095.
March 2, 2027
- If you ARE doing automatic distribution of Form 1095 to all employees, this is your deadline to complete the distribution.
- If you're NOT doing automatic distribution of Form 1095, you need to post a clear employee notice for furnish-upon-request today through October 15th, 2027.
- New Jersey, Rhode Island, and Washington DC still require Form 1095 to be distributed by this date.
March 31, 2027
- Federal electronic filing deadline.
- State filing deadline for California, New Jersey, and Rhode Island.
April 30, 2027
- Washington DC filing deadline
Keep this in mind: you need to decide whether you're automatically sending Form 1095 to everyone (March 2, 2027 deadline) OR posting a notice telling employees they can request them. This is due to the changes from the Paperwork Burden Reduction Act that was signed at the end of 2024. If an employee requests a form, provide it by January 31 or within 30 days of the request, per the permanent IRS extension.
The request option applies to federal requirements only. California, New Jersey, Rhode Island, and Washington D.C. still expect forms to be furnished to covered residents. Learn more at our ACA Reporting hub.
The Bottom Line
ACA compliance involves federal requirements, state-specific rules, and a year's worth of data, which is best prepared for early. Penalties for failing to file or furnish correct forms are adjusted for inflation each year. A review now, covering your data, safe harbors, and deadlines puts you in a stronger position heading into 2027.
If you'd like support with ACA reporting, our ACA Reporter works alongside your team to prepare, file, and distribute your forms accurately and on time. Contact us to learn more.
