Blog

How do You Apply for an ACA Filing Extension?

Jun 11, 2022

Steve Elworth

Last Updated: June 2026

If you cannot file your ACA forms with the IRS on time, you can request a 30-day extension using Form 8809. It is a simple, one-page form, and for ACA reporting the first extension is granted automatically when you file it before your deadline.

Below, we walk through who can request an extension, what it does and does not cover, and what to do if the deadline has already passed.

Navigate This Article: 

 

What Is an ACA Filing Extension?

An ACA filing extension gives Applicable Large Employers (ALEs) an extra 30 days to file Forms 1094-C and 1095-C with the IRS. You request it by submitting Form 8809, the Application for Extension of Time to File Information Returns, on or before your original filing deadline.

One point to understand up front: this extension applies to filing your forms with the IRS only. It does not extend the separate deadline to furnish 1095-C forms to your employees. We cover that difference below.

 

How Do I Request an ACA Filing Extension?

aca filing extension form 8809

 

To request your extension:

  1. Complete Form 8809. You can file it electronically through the IRS FIRE system or on paper.
  2. Submit it on or before your original IRS filing deadline. A late Form 8809 will not be accepted.
  3. That is it. For Forms 1094-C and 1095-C, the first 30-day extension is automatic. You do not need to sign the form or explain why you need more time, as long as you file it on time.

If you need a second 30-day extension, the process is different. A second extension is not automatic, requires a reason, and is rarely granted, so it is best to plan around the first 30 days.

 

 

 

When are ACA Forms Due?

Before requesting an extension, it helps to know the deadlines you are working against. ACA reporting has two layers: federal deadlines that apply to every ALE, and state deadlines that apply if you have employees in certain states.

Federal deadlines

For the current reporting year, the federal deadlines are:

  • Furnish 1095-C forms to employees:
    • If you are making the forms available to employees upon request, you must post a notice for employees, that includes how to request their 1095-C form, by January 31
    • If you are planning to distribute 1095-C forms to all employees, either a paper or an electronic copy of the form, this must be completed by March 2. This includes the permanent 30-day extension from the original deadline of January 31.
  • Paper file with the IRS: on or around February 28, available only to employers filing fewer than 10 total information returns.
  • E-file with the IRS: March 31. Required for any employer filing 10 or more returns of any type combined.

Form 8809 extends the IRS filing deadlines above by 30 days. It does not extend the furnishing deadline.

State deadlines

Several states set their own ACA reporting deadlines, and some fall earlier than the federal dates:

  • California: furnish to employees by January 31, then file with the state by March 31, with an automatic extension to file until May 31.
  • New Jersey and Rhode Island: furnish by March 2, then file with the state by March 31.
  • Massachusetts: furnish and file Form MA 1099-HC by late January.
  • Washington, D.C.: file by April 30.

NOTE: State deadlines change periodically, and not every state offers an extension. For the full, current breakdown, see our ACA reporting deadlines guide.

 

Frequently Asked Questions about ACA Filing Extensions

No. Form 8809 extends only your deadline to file with the IRS. It does not extend the deadline to furnish 1095-C forms to your employees.

The furnishing deadline already has a permanent automatic 30-day extension built in, which is why it falls in early March rather than on January 31. Because that extension is already applied, it cannot be pushed back any further. Plan to get forms to employees by the furnishing deadline whether or not you have requested a filing extension.

ACA reporting applies to Applicable Large Employers, or ALEs. You are generally an ALE if you had 50 or more full-time or full-time-equivalent employees during the prior calendar year. The IRS counts an employee as full-time if they work at least 130 hours in a month.

If you are below that threshold, you usually are not required to file Forms 1094-C and 1095-C, though self-insured small employers may still have reporting obligations under separate rules.

File as soon as you can. The penalties for filing late are lower than the penalties for not filing at all, and the IRS generally reduces the amount for forms that are filed or corrected within 30 days of the deadline.

If you forgot to submit Form 8809 before the deadline, you can no longer request an extension for that year, but submitting your forms quickly still limits your exposure. Acting promptly is always better than waiting.

These are filing and furnishing penalties under Sections 6721 and 6722 of the tax code. They apply when forms are filed or furnished late, incompletely, or with errors. They are separate from the employer mandate penalties, which we cover below.

The current per-form penalty amounts are:

  • $60 per form if you correct it within 30 days of the deadline.
  • $130 per form if you correct it after 30 days but before August 1.
  • $340 per form if you do not file or furnish it.
  • $680 per form for intentional disregard, with no annual cap.

One detail that surprises many employers: these penalties apply separately for filing with the IRS (Section 6721) and for furnishing forms to employees (Section 6722). A single form missed on both sides can therefore carry roughly $340 for not filing and an additional $340 for not providing the 1095-C form for each employee

These filing penalties are different from the employer mandate penalties that apply when coverage is not affordable or does not meet minimum value. To learn about those, see our ACA affordability percentage guide.

In most cases, employees do not need to attach Form 1095-C to their federal tax return. They should keep it with their records, but it is not required to file in the way a W-2 is.

Employers also have a newer option for getting forms to employees. Instead of automatically mailing a 1095-C to everyone, you may post a clear, visible notice that employees can request a copy, then provide it within the required time frame. This can reduce the administrative load on your HR team.

One caveat: this alternative method does not apply to employees who live in California, New Jersey, or Rhode Island. Those states have their own furnishing rules, so employees there still need to receive their forms directly.

It depends on the state. Form 8809 is a federal form, so it only extends your IRS filing deadline. It does not apply to state filings.

Some states build in their own flexibility. California, for example, offers an automatic extension to file with the state until May 31. Others follow their own schedule with no extension option. If you have employees in multiple states, check each state's rules separately, since federal timing does not cover you at the state level.

For state-by-state deadlines, see our 2026 ACA reporting deadlines guide.

 

Stay Ahead of ACA Deadlines with Points North

Filing extensions exist for a reason, and there is no shame in needing one. Still, the smoothest path is to keep your ACA data accurate throughout the year so deadlines arrive without the scramble.

That is what ACA Reporter from Points North is built to do. The software tracks employee eligibility across variable hours and multiple locations, generates accurate 1095-C forms, and e-files with the IRS using built-in validation to catch errors before they turn into penalties. Current IRS and state rules are updated automatically, so your team is not rechecking thresholds by hand every January.

Learn more about ACA Reporter, or contact Points North today with the form below to schedule a free demo and see how much simpler ACA reporting can be.

 
Newer Post > < Older Post

Ready to Reclaim Your Time?

Whether you're managing certified payroll reporting and compliance, ACA reporting, or something in between — manual processes and disconnected systems can quietly drain your team's time and energy:

  • How much time do you spend gathering data or fixing reporting errors?
  • What's the cost of that time — in dollars, stress or missed opportunities?
  • Are you confident in your compliance approach, or just hoping nothing slips through?
  • What could your team achieve with smarter systems and fewer headaches?

The right software solution can free you from outdated processes and help you focus on what matters most. Let's talk about how Points North can help.

Trends & Insights

Related Articles

See More