July 12, 2016 – Form 1094/1095 – ACA Compliance

Alerts

Haven’t filed your 2015 1094/1095 ACA Forms?

STILL FILE

The IRS is still accepting late electronic filing for 2015 1094/1095 forms. The forms were initially due at ET Midnight on June 30, 2016.  However, midday on June 30, the IRS released a bulletin advising filers that the IRS will continue accepting 1094/1095 e-filed submissions after June 30.

Most notably:

  • The AIR system will continue to accept information returns filed after June 30, 2016. In addition, you can still complete required system testing after June 30, 2016.
  • If any of your transmissions or submissions were rejected by the AIR system, you have 60 days from the date of rejection to submit a replacement and have the rejected submission treated as timely filed.
  • If you submitted and received “Accepted with Errors” messages, you may continue to submit corrections after June 30, 2016.

While the IRS bulletin did not specifically extend the filing deadline, it did remind filers that late filers may not necessarily be assessed penalties under section 6721 “if the reporting entity has made legitimate efforts to register with the AIR system and to file its information returns, and it continues to make such efforts and completes the process as soon as possible.”

Bottom Line:  If you have not filed your 2015 1094/1095 forms, file them as soon as possible

The IRS bulletin released on June 30, 2016 via its Quick Alerts subscription service is available here: https://content.govdelivery.com/accounts/USIRS/bulletins/152ce7b

Please contact us if you have questions or are in need of assistance with filing.