ACA modules measure hours to identify full-time employees, generate Forms 1095-C and 1094-C, and transmit them electronically to the IRS. Whether you are in scope is a count you own: an employer is an applicable large employer if it averaged at least 50 full-time employees, including full-time equivalents, during the prior calendar year, where a full-time employee averages at least 30 hours of service per week or 130 hours in a calendar month and related companies under section 414 are combined [1].
Electronic filing now catches small filers
The 10 return rule pulled small employers into electronic filing. IRS instructions state that if you are required to file 10 or more information returns during the year you must file the forms electronically [2], and the Affordable Care Act Information Returns page repeats that threshold and requires a new filer to apply for a Transmitter Control Code [3]. The count works in aggregate across return types, so a handful of Forms 1095-C plus W-2s and 1099s can cross it.
The dates attached to the 2025 forms
Statements for 2025 are due to employees by March 2, 2026, and the returns are due to the IRS by March 2, 2026 on paper or March 31, 2026 electronically [2]. An employer using the alternative furnishing method posts a clear, conspicuous, and accessible website notice by March 2, 2026, keeps it there through October 15, 2026, and furnishes a statement within 30 days of a request [2].
Affordability is a calculation you configure
The required contribution percentage under section 36B(c)(2)(C)(i)(II) is 9.96 percent for plan years beginning in calendar year 2026, set by Revenue Procedure 2025-25 [4]. Software applies whichever safe harbor you select, using Form W-2 wages, rate of pay, or the federal poverty line, and reports it in the line 16 codes [2]. You choose the safe harbor and set the lowest cost self only contribution so it clears the test.
The filing obligation does not transfer
Each applicable large employer member files a Form 1095-C for its full-time employees with the Form 1094-C transmittal [1][2], and a vendor transmitting on your behalf does not change whose return it is. This is general information about published requirements rather than legal or tax advice.