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January 2, 2025

ACA Reporting Relief for Employers Goes into Effect: New relief affects Form 1094/1095 reporting and employer mandate penalties

On December 17, 2024, Congress passed the “Paperwork Burden Reduction Act” (H.R. 3797) and the “Employer Reporting Improvement Act” (H.R. 3801). These bills ease the administrative burden for Affordable Care Act (ACA) reporting by amending the filing and distribution requirements for Forms 1094 and 1095 and placing enforcement limitations on the IRS’s employer mandate penalty assessments. President Biden signed both bills into law on December 23, 2024.

This alert summarizes the new relief and is relevant for ACA applicable large employers, as well as smaller employers sponsoring self-insured medical plans (including level-funded coverage). The reporting relief is available for 2024 Form 1094 and 1095 reporting.