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Don't Let 2026 ACA Deadlines Sneak Up on You

Written by Craig Rees | Sep 25, 2025 5:21:11 PM

Look, we've all been there. It's easy to think ACA reporting season is ages away when you're dealing with everything else on your plate. But here's the thing: 2026 will be here before you know it, and scrambling at the last minute is a recipe for disaster. We've seen too many organizations get burned by waiting too long. Do yourself a favor and start auditing your systems now while you still have breathing room. 

 

Get Your Safe Harbors and Measurement Periods Straight 

Let's be honest, safe harbors and measurement periods can be confusing, even when you think you've got them figured out. Whether you're using W-2, rate of pay, or federal poverty line safe harbors, now's the time to double-check that you're calculating everything correctly and have your documentation in order. 

Same goes for your measurement periods. Make sure your look-back periods and stability periods actually make sense for your organization. And remember, you can't just change these mid-year without creating a compliance mess. Trust us on this one.

Your Payroll Data Is Probably Messier Than You Think 

We're not trying to scare you, but inaccurate payroll data causes more ACA headaches than just about anything else. Every single data point matters. Employee classifications, hours tracked, offer codes, coverage dates, all of it needs to be spot-on throughout 2025 for your 2026 reporting to work. 

Do yourself a huge favor and audit your payroll systems now. Pay special attention to your variable-hour folks, seasonal workers, and anyone who's changed status. If your payroll, HRIS, and benefits systems aren't talking to each other properly, that is a critical fix. Disconnected systems are basically guaranteed to create reporting nightmares. 

The Dates You Absolutely Cannot Miss 

Okay, this is the crucial stuff. Put these in your calendar right now, we're not kidding: 

January 31, 2026 

  • California's 1095 distribution deadline (state requirement)
  • Federal 1095 Forms: If you're NOT doing automatic distribution of 1095s, you need to post a clear employee notice by this date 

March 2, 2026 

  • If you ARE doing automatic distribution of 1095s to all employees, this is your deadline to complete the distribution
  • New Jersey, Rhode Island, and Washington DC still require 1095 form to be distributed by this date. 

March 31, 2026 

  • Federal filing deadline 
  • State filing deadline for California, New Jersey, and Rhode Island 

April 30, 2026 

  • Washington DC filing deadline 

Here's something really important: you need to decide whether you're automatically sending 1095s to everyone (March 2, 2026 deadline) OR posting a notice by January 31, 2026 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. 

The Bottom Line 

Here's the deal: you can't fake your way through ACA compliance, and you definitely can't handle it with a last-minute panic. Between federal requirements and state-specific rules, there's just too much to juggle. 

The IRS is getting better at catching mistakes, and penalties keep going up. So do your future self a favor. Start your compliance review now, clean up your data, understand your safe harbors, and give yourself some cushion. Let's make 2026 the year you're ahead of the game instead of playing catch-up. 
 
By the way, if you're tired of managing all this manually, check out ACA Reporter. We've helped hundreds of companies navigate these exact deadlines and the entire ACA compliance process without the headaches. Reach out – we're here to help.