Finalized Rule on Required Electronic Filing Threshold

Tuesday March 7th, 2023

Estimated time to read: 30 seconds

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The IRS released their final rule on electronic filing requirements for specified returns. This impacts a number of returns filed to the IRS including forms related to Affordable Care Act (ACA) reporting, specifically 1094 and 1095-B and 1095-C.   

Key Takeaways

  • It reduces the electronic filing threshold from 250 forms to 10.
  • It requires employers to aggregate their various returns when calculating and deciding if they have met the required electronic filing threshold.
  • Employers will be subject to electronic filing of forms including W-2, 1099, 5498, 1042-S, 1097-BTC, 1098, 1098-C, E, Q, T, 3921, 3922, 8027 and W-2G, in addition to ACA reporting.
  • This change goes into effect for required filing after January 1, 2024.


There are stiff penalties associated with noncompliance unless an employer can obtain a waiver for undue hardship or religious reasons. Good-Faith Relief for ACA reporting ended in 2022. It remains to be seen whether there will be any additional grace provided with this new requirement beyond that.

Stay tuned for additional guidance.

To learn more about how you and your clients can benefit from isolved’s ACA solutions, contact your sales executive at 800.300.3838.

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