Filing & ReportingAnnual
ACA MEC Reporting: Forms 1094-B / 1095-B
IRC § 6055; ACA § 6055
Self-insured non-ALE plan sponsors must file Forms 1094-B / 1095-B reporting minimum essential coverage for each covered individual. For ALEs with self-insured plans, this info goes on 1095-C Part III instead. For fully insured, the carrier files.
ResponsibleClient/Other TPA (compliance TPA)
Deliver ToIRS (1094-B/1095-B filed); Covered individuals (1095-B furnished)
DeadlineFile with IRS: by Feb 28 (paper) or Mar 31 (electronic); Furnish to individuals: by Mar 2
Current Fee / Rate Information
No filing fee. Required for self-insured plans not filing as ALEs. Electronic filing required for 10+ forms.
Last reviewed: October 2026
Non-Compliance Penalties
Same penalty structure as 1094-C/1095-C. For returns due in 2027: $340 per return, capped at $4,191,500 a year ($1,397,000 if average gross receipts are $5 million or less). Source: IRS Rev. Proc. 2025-32.
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