ACA Reporting Requirements for Employers by Individual U.S. State

Check back periodically as we update this page when more info is released by states.  This information is current as of September 15, 2025.

Form Distribution Requirements to Applicable Recipients

California

Direct consultations with two tax advisors at the California Franchise Tax Board (FTB) indicate:

Employers that offer health coverage through a self-insured health plan must make available Federal Form 1095-B or 1095-C to applicable employees (and any individuals receiving Minimum Essential Coverage through the employer) by January 31 of the year following the coverage year.

  • No duplicate required: If you have already furnished federal Form 1095 to an individual for federal purposes, it is not necessary to provide an additional copy for California purposes.
  • Electronic furnishing: Employers may satisfy distribution by making forms available via a secure portal or download link (after verification), provided they comply with federal electronic delivery standards (e.g., employee consent, accessibility).
  • Paper furnishing: A paper copy must be sent by mail upon request from any employee or covered individual.

Additional Source:  FTB Publication 3895C

Massachusetts

Massachusetts requires organizations physically furnish Form MA 1099-HC to applicable residents who are enrolled in employer-sponsored health insurance coverage — not to those merely offered coverage. Organizations are required to provide the forms to employee residents by January 31st.  For fully insured plans, typically the health insurance carrier takes care of this requirement.   Employers will want to check with their insurance carriers to make sure this requirement is being met.

Additional Source:  Mass.gov

New Jersey

Employers must report on health coverage enrollees who were a New Jersey resident and to whom the employer provided minimum essential coverage. According to direct communication with the New Jersey Department of the Treasury, Division of Taxation:

  • Employers must ensure that applicable New Jersey resident employees have access to Form 1095 by March 3 of the given year.
  • Acceptable furnishing methods include:

    • Secure download link (with employee verification).
    • Email attachment.
    • Traditional mail (optional, not mandatory).
  • No affirmative consent is required under New Jersey law for electronic delivery if access is ensured.

Additional Source:  https://nj.gov/treasury/njhealthinsurancemandate/employers.shtml 

Rhode Island

Rhode Island requires organizations physically furnish Form 1095-B (typically carriers or self-insured employers that are not applicable large employers) or Form 1095-C (typically self-insured applicable large employers) to applicable residents who are enrolled in employer-sponsored health insurance coverage — not to those merely offered coverage. Organizations are required to provide the forms to employee residents by March 2nd.  For fully insured plans, typically the health insurance carrier takes care of this requirement.   Employers will want to check with their insurance carriers to make sure this requirement is being met.

Source:   https://tax.ri.gov/guidance/health-insurance-mandate

Vermont

  • Follow federal requirements only – no additional Vermont-specific distribution obligations.
  • As of 2024, must provide notice that Forms 1095 are available upon request (no automatic distribution required)

Additional Source:  https://info.healthconnect.vermont.gov/learn-more/filing-taxes/tax-form-1095-faq 

Washington, D.C.

Employers must report on employees who are District of Columbia residents to whom the employer provided minimum essential coverage. A “resident,” for purposes of reporting, is any individual during the tax year in question who either had a home or mailing address within the District or for whom wages were withheld and paid to the District.  Guidance provided by a representative of the Office of Tax & Revenue indicates:

  • Employers must notify applicable employees of their right to request a Form 1095.
  • Requested forms must be provided by March 3, or within 30 days of the request  of the given year.  Compliance with the IRS requirement to furnish an annual statement of health coverage to employees or covered individuals (Form 1095-B or Form 1095-C) is sufficient.
  • Electronic furnishing is acceptable if:

    • Employees are notified of availability.
    • Employees provide consent for electronic delivery.
    • Forms are accessible via a secure download link or portal.
    • Mailing hard copies upon request.

Additional Source:  https://otr.cfo.dc.gov/sites/default/files/dc/sites/otr/publication/attachments/FAQ%20reporting%20SRP%20%288.6.19%29.pdf 

 

 

Electronic Filing Requirements by State

 

State What must be e-filed / How Electronic filing deadline Penalties (as stated by the state for this filing) Official source
California MEC information returns (1094-B/C & 1095-B/C) filed with FTB; electronic filing via FTB MEC FX Portal (UI or A2A). Mar 31 (automatic extension to May 31). Files must be “Accepted” by the deadline to be timely. (Franchise Tax Board) $50 per covered individual if filed after May 31 (post-extension). FTB does not impose a penalty for failure to furnish statements by Jan 31. (Franchise Tax Board) FTB “Report Health Insurance Information” page (deadlines, channels, penalty). (Franchise Tax Board)
Massachusetts If the employer (or carrier) issues MA 1099-HC, the employer must transmit 1099-HC data electronically to DOR (MassTaxConnect XML/bulk file). Paper filing by employers is not allowed. January 31st; Employers are to submit via MassTaxConnect. (DOR updates appear annually.) (Mass.gov) $50 per individual, up to $50,000, for failing to issue required MA 1099-HC. (Penalty statement on DOR page.) (Mass.gov) DOR “Health Care Reform for Employers” (submission method, no paper; penalty), plus bulk-file resources. (Mass.gov)
New Jersey 1095 data must be transmitted to the NJ Division of Taxation; state accepts IRS 1095 forms (or NJ-1095). E-file options include state systems listed on the Mandate site. Mar 31 (e.g., Mar 31, 2025 for TY2024). (NJ.gov) The employer page does not state a penalty for failure to file the information returns. (General e-file mandate page exists for wage/1099 reporting and lists “1094/1095” among e-filed items, but no penalty is specified there for ACA filings.) (NJ.gov, NJ.gov) NJ Treasury “Employers & Coverage Providers” (deadlines) and NJ e-file mandate page (electronic requirement). (NJ.gov, NJ.gov)
Rhode Island ACA/Mandate information returns may be uploaded via the Division’s portal; RI accepts IRS AIRS 1094/1095 files or a flat CSV; no pre-registration needed. Mar 31 (permanent change effective TY2022 filings starting 2023). The Division’s ACA reporting FAQ/Advisory does not state an employer filing penalty (separate guidance covers the individual shared-responsibility penalty). (Rhode Island Department of Revenue) RI Division of Taxation ACA Reporting FAQ (formats/process) and Advisory 2022-29 (permanent Mar 31 filing deadline). (Rhode Island Department of Revenue)
District of Columbia All ACA information returns must be filed electronically via MyTax.DC.gov (pipe-delimited .txt). DC follows IRS furnish date; filing is 30 days after the IRS deadline. Example: For TY2023, Apr 30, 2024 (30 days after IRS). Same “+30 days” rule applies each year. (Office of Tax and Revenue) No penalty is imposed for failure to file these informational returns (because no tax is shown on the return), per OTR Notice 2020-04. DC OTR Electronic Filing Specifications (deadline & format) and OTR Notice 2020-04 (no penalty; electronic-only). (Office of Tax and Revenue)