Jan 13, 2016

Deadline Extensions for Affordable Care Act Information

In Notice 2016-4, released on December 28, 2015, the Service extended the due dates for the Affordable Care Act (ACA) information reports that certain employers and coverage providers must issue to individuals and file with the Service.  The Notice extends the reporting deadlines as follows:

Old Deadline New Deadline
Information reports to individuals

  • 2015 Forms 1095-B and 1095-C
February 1, 2016 March 31, 2016
Information reports filed with the Service

  • 2015 Forms 1094-B & 1095-B
  • 2015 Forms 1094-C & 1095-C
February 29, 2016 (paper)
March 31, 2016 (electronic)
May 31, 2016 (paper)
June 30, 2016 (electronic)

The Notice provides employers and coverage providers with additional time to gather, analyze and report the required information. Notwithstanding this relief, employers and other coverage providers are encouraged to furnish statements and file the information returns as soon as they are ready.

In light of the relief, the provisions regarding automatic and permissive extensions of time for filing information returns and permissive extensions of time for furnishing statements will not apply to the extended due dates. Employers and other coverage providers that fail to comply with the extended deadlines will be subject to penalties, unless abated by the Service for reasonable cause.

Because of the extended deadline, some individuals might not receive their forms by the time they file their 2015 tax returns. The Notice indicates that such individuals will not be required to file an amended return, but they should maintain the forms with their tax records.