The Affordable Care Act continues to shape employer obligations in 2026. While the core framework has been in place for over a decade, regulatory updates, reporting requirements, and enforcement priorities continue to evolve. Here's a practical checklist for small employers.
Employer Shared Responsibility: If you have 50 or more full-time equivalent employees, you are an Applicable Large Employer (ALE) and must offer minimum essential coverage to full-time employees or face potential penalties. Review your FTE count annually — part-time hours count toward the threshold.
Minimum Value and Affordability: Coverage offered to full-time employees must meet minimum value standards (covering at least 60% of the total allowed cost of benefits) and must be affordable based on the employee's household income. The affordability threshold is updated annually.
Forms 1094-C and 1095-C: ALEs must file these forms with the IRS and distribute 1095-C forms to employees. Deadlines and electronic filing thresholds have changed in recent years — confirm current requirements with your benefits advisor or tax counsel.
Summary of Benefits and Coverage (SBC): Employers must provide an SBC to employees during open enrollment and within certain timeframes for new hires and special enrollment events. Ensure your SBC is current and accurately reflects your plan.
COBRA Notices: Qualifying events must trigger timely COBRA notices. Review your COBRA administration process to ensure notices are going out within required timeframes.
Mental Health Parity: Plans must provide mental health and substance use disorder benefits at parity with medical and surgical benefits. This requirement has received increased regulatory attention — review your plan documents carefully.
Working with a knowledgeable benefits advisor is the most reliable way to stay on top of ACA compliance. The rules are complex, and the penalties for non-compliance can be substantial.
