With the release of IRS Notice 2016-4, the Internal Revenue Service (IRS) delayed employer reporting and distribution of statements to employees.  According to the IRS, the purpose of the delay was to provide employers (reporting entities) with additional time to implement systems, collect data and assemble the information for the reporting requirements.

Section 6055 and 6056 were added to the Internal Revenue Code by the Affordable Care Act (ACA) and imposed the requirement to file and furnish annual information returns and statements regarding coverage provided.  The reporting requirement applies to applicable large employers (ALE), those with 50 or more full-time equivalent employees (FTEs) in the previous year, to file.

The delay in reporting will now result in the following deadlines:

• 1095-B and 1095-C:  March 31, 2016
• 1094-B and 1094-C (paper):  May 31, 2016
• 1094-B and 1094-C (electronic):  June 30, 2016

It is important to understand that the adjusted deadlines only apply to 2015 calendar year forms (due in 2016).  Additionally, reporting entities will not have an opportunity to request an extension.

For any employer that is prepared for ACA reporting, the IRS is ready to accept all forms, regardless of the delay.

Reporting entities that fail to file an information return in a timely manner could be subject to penalties for non-compliance.  As a result, it is critically important for those reporting entities to provide a timely submission of employer reporting.