You filed your Forms 1094-C and 1095-C with the IRS. AIR accepted the transmission. Filing season is over. Right?

Not necessarily.

California, New Jersey, Massachusetts, Rhode Island, and Washington, D.C. have their own health coverage reporting requirements tied to state or district individual mandates. If you have employees living in those jurisdictions, federal ACA reporting may be only one part of your job.

And, sadly, these aren’t five copies of the same rule.

Some states accept federal Forms 1095-B and 1095-C for state reporting, while Massachusetts requires Form MA 1099-HC and a separate HIRD filing. Deadlines vary by state, and reporting may be handled by the insurer or the self-insured employer, depending on the funding arrangement. Importantly, federal furnish-on-request relief does not automatically eliminate state furnishing requirements.

For multi-state employers, crossing the federal ACA reporting finish line is often only part of the process, with state reporting obligations still to be addressed.

Federal filing is only part of the picture. Selerix supports ACA reporting from data review and federal e-filing through employee distribution and state-specific reporting requirements. Explore Selerix ACA Compliance

Which States Have Their Own ACA Reporting Requirements?

Five jurisdictions currently operate the state-level health coverage reporting regimes most likely to create separate employer filing or furnishing responsibilities: 

• California
• New Jersey
• Massachusetts
• Rhode Island
• Washington, D.C.

Several of these requirements emerged after the federal individual shared-responsibility payment was reduced to $0 beginning in 2019. Massachusetts is the notable exception: its individual health coverage mandate and Form MA 1099-HC reporting system predate the federal ACA.

These are individual coverage mandates, not separate state employer mandates requiring every employer to offer insurance. The employer-side issue is reporting: states need coverage information to administer their individual mandates.

Vermont also has an individual coverage requirement, but as we’ll explain below, it does not currently operate the same routine separate employer 1095 filing cycle as the five jurisdictions above.

State ACA Reporting at a Glance

One important caveat before you bookmark the table: always confirm the current filing-year instructions before transmitting. States can change technical specifications, portals, and dates from year to year.

Jurisdiction	Who generally files?	Forms / data accepted	General furnishing deadline	General filing deadline	Penalty exposure
California	Entities providing MEC; self-insured employers generally file. If insurer reports insured coverage, employer generally does not duplicate it.	Federal Forms 1094-B/1095-B or 1094-C/1095-C, as applicable	January 31	March 31; automatic penalty-free extension through May 31	After May 31, FTB may assess $50 per covered individual for missing state filings.
New Jersey	Insurers, employers, plan sponsors, and other coverage providers; employer can become responsible if its insurer or multiemployer plan does not file	NJ-1095, 1095-B, or qualifying 1095-C coverage data	Early March; for 2025 coverage, March 2	March 31 under current guidance	State reporting liability can attach when required filing is not completed; employers should confirm the current penalty rule for the filing year.
Massachusetts	Carriers and certain employers for MA 1099-HC; employers with 6+ MA employees also file HIRD	MA 1099-HC plus separate HIRD	MA 1099-HC: Jan. 31	MA 1099-HC reporting: Jan. 31; HIRD: Dec. 15	Failure to issue/report MA 1099-HC when required: $50 per individual, up to $50,000 per year per violator.
Rhode Island	Employers/plan sponsors, carriers and other entities providing MEC to RI residents; insurer filing can satisfy employer obligation	Federal ACA data / approved state formats	March 2	March 31	RI says late or incorrect filings may violate state law and are reviewed case by case.
Washington, D.C.	Employers or plan sponsors, carriers and other entities providing MEC	1094-B/1095-B, 1094-C/1095-C, or 1095-A data, as applicable	Same deadline as IRS furnishing requirement under current instructions	Approximately 30 days after IRS filing deadline; April 30	OTR’s published guidance says its general failure-to-file formula produces no monetary penalty because the information return shows no tax, although filing remains mandatory.

The similarities are useful, but the differences are where employers get into trouble.

California ACA Reporting

California’s individual mandate requires entities providing minimum essential coverage to report that coverage to the California Franchise Tax Board (FTB).

For employers, plan funding matters. If an employer provides coverage through an insured plan and the insurance carrier reports the required coverage information to FTB, the employer generally does not need to submit a duplicate state return.

Employers sponsoring self-insured coverage, however, generally have their own reporting responsibility for the individuals enrolled in that coverage.

California makes federal data relatively reusable. The same federal Forms 1094-C and 1095-C used for IRS reporting can be provided to FTB for applicable employer coverage. Self-insured employers complete Part III of Form 1095-C to identify the individuals who actually had minimum essential coverage.

State returns are due March 31 following the coverage year, with an automatic extension through May 31 before FTB begins imposing late-filing penalties. After that date, FTB may assess $50 for each individual for whom coverage should have been reported. Employers filing 10 or more information returns generally must file electronically.

California also retains a direct furnishing requirement: current FTB instructions require the applicable Form 1095-C to be provided to covered individuals by January 31 following the coverage year. FTB says it does not impose its own penalty for missing that January 31 furnishing deadline, but the state requirement itself remains.

That last point becomes especially important now that federal furnishing rules have changed.

More on that below.

New Jersey ACA Reporting: NJ-1095 Filing

New Jersey is particularly important for multi-state employers because being headquartered somewhere else doesn’t get you out of the filing requirement.

The New Jersey Division of Taxation explicitly says out-of-state employers and coverage providers must report applicable coverage for New Jersey residents.

Who actually transmits depends on the arrangement.

For fully insured plans, the insurer generally reports the coverage. Employers should confirm that the insurer will do so, because New Jersey states that the employer must file if the insurer fails to meet its obligation. Similar rules apply when a multiemployer plan sponsor is expected to report.

Self-insured employers have a more direct role. A self-insured ALE can submit a fully completed Form 1095-C, Form 1095-B, or NJ-1095 as applicable. But there’s a wrinkle worth remembering:

A federal 1095-C containing only Parts I and II does not satisfy New Jersey’s coverage-reporting requirement. New Jersey needs the coverage information in Part III.

The state does not require a separate Form 1094, although it will accept one as part of an electronic file containing valid 1095 data.

NJ 1095 filing is also electronic only. Current guidance directs filers with 50 or more forms to the state’s MFT SecureTransport system, while smaller filers use the NJ-1095 process. Corrections sent to the IRS must also be submitted to New Jersey.

Under the current annual schedule, state filings are due March 31. For 2026 coverage, New Jersey required the applicable 1095 to be furnished to the primary enrollee by March 2, 20276.

And New Jersey is unusually explicit about federal furnish-on-request relief: It does not follow the federal practice for state purposes. The state says a 1095 must still be sent to the applicable primary enrollee. 

Massachusetts ACA Reporting: Form MA 1099-HC and HIRD

Massachusetts is the odd one out, largely because it was doing this before the ACA existed.

Instead of simply asking employers to send another copy of federal Form 1095-C, Massachusetts uses its own Form MA 1099-HC, which Massachusetts residents use to document health coverage for their state tax return.

Employers and carriers sponsoring applicable employment-based coverage must provide or arrange to provide Form MA 1099-HC to Massachusetts residents by February 1, 2027 and electronically report the corresponding information to the Department of Revenue. In practice, insurance carriers commonly handle the MA 1099-HC for fully insured employer plans. If the carrier is not filing on the employer’s behalf, the employer may need to transmit the data itself through MassTaxConnect. Paper filing is not accepted.

Failure by a carrier, employer, or other sponsor that is obligated to issue and report Form MA 1099-HC can result in a penalty of $50 per affected individual, up to $50,000 per year per violator.

But Massachusetts has another filing HR teams need to keep separate from MA 1099-HC.

The Massachusetts Health Insurance Responsibility Disclosure (HIRD) is an annual state filing that collects employer-level information about health insurance offered to employees. 

Employers that had six or more Massachusetts employees during the prior 12 months, including certain out-of-state employers with Massachusetts workers, are generally required to submit the HIRD form through MassTaxConnect. This reporting requirement is separate from federal ACA Forms 1094-C and 1095-C

Rhode Island ACA Reporting

Rhode Island’s individual health insurance mandate took effect January 1, 2020, and its reporting rules apply to employers or other sponsors of employment-based plans offering minimum essential coverage to Rhode Island residents, as well as carriers and other applicable entities.

If an insurer completes the required reporting for an employer’s fully insured plan, the employer generally does not need to submit the same coverage information again.

Rhode Island allows employers to leverage much of the same coverage information used in federal ACA reporting. The Division has supported federal-style ACA data as well as an approved flat-file process, and covered entities submit through Rhode Island’s Individual Mandate reporting portal.

The state permanently aligned its deadlines more closely with the federal cycle in 2022:

• Statements to individuals: March 2
• State filing: March 31

If March 2 falls on a weekend or holiday, the furnishing deadline moves to the next business day.

What about penalties?

Rhode Island’s published rulemaking guidance does not give employers a neat “$X per form” reporting penalty to plug into a spreadsheet. Instead, the Division has stated that late filings or incorrect data may violate Rhode Island law and that cases will be evaluated based on their individual facts and circumstances.

In other words: the absence of a simple penalty table is not permission to skip the filing.

Washington, D.C. ACA Reporting

Washington, D.C.’s individual health coverage requirement applies to District residents, and its reporting law defines applicable entities to include employers or other sponsors of employment-based health plans, along with carriers and certain governmental entities providing minimum essential coverage.

For the current reporting cycle, D.C. tells applicable entities to report the same general form families used federally:

• Forms 1094-B and 1095-B
• Forms 1094-C and 1095-C
• Form 1095-A, where applicable

But don’t send the IRS file somewhere and assume D.C. receives it.

D.C. requires a separate direct electronic filing through MyTax.DC.gov, even where a filer participates in the IRS Combined Federal/State Filing program. All D.C. health coverage filers must file electronically, regardless of volume.

The technical format also differs: D.C.’s current instructions require health coverage bulk files in pipe-delimited text format, not the XML format used by IRS AIR.

Under current rules, the D.C. filing deadline is 30 days after the IRS deadline. For 2026 coverage, that made the D.C. deadline April 30, 2027. D.C. currently follows the IRS furnishing deadline for recipient statements; for that same coverage year, the furnishing deadline was March 2, 2026.

Interestingly, D.C.’s published OTR FAQ says its general failure-to-file penalty is calculated from tax shown on a return, and because these health information returns show no tax, no monetary failure-to-file penalty is imposed under that formula. D.C. nevertheless requires the returns, and employers should not confuse “no penalty under that formula” with “filing is optional.”

What About Vermont and Other States?

Vermont does have an individual requirement to maintain minimum essential coverage. But it does not currently run the same routine employer 1095 filing cycle as California, New Jersey, Rhode Island, or D.C.

Instead, Vermont law contains a contingency. If the federal requirement for coverage providers to furnish statements under Section 6055 is ever suspended or eliminated, employers, carriers, and other entities providing minimum essential coverage to Vermont residents would then be required to report that information to the Vermont Department of Taxes.

Requirements in Vermont are worth checking annually, but for now it is not another state to add to this year’s 1095 upload queue. 

How Federal Furnish-on-Request Rules Interact With State Mandates

This is probably the easiest new reporting trap to fall into.

At the federal level, employers can now use the Form 1095-C furnish-on-request process when they satisfy the applicable website-notice and request requirements. We break down those rules in New ACA Reporting Rules: What Employers Need to Know.

But federal relief is not blanket state relief.

New Jersey expressly says its own rules still require a 1095 form to be sent to the applicable primary enrollee, even though the IRS allows certain federal statements to be furnished only upon request. California’s current instructions likewise retain a January 31 furnishing requirement for applicable coverage statements. Massachusetts still requires MA 1099-HC delivery, and Rhode Island maintains its own March 2 statement deadline.

So before turning off automatic 1095 distribution across your workforce, ask a second question: Where do the people receiving these forms live? 

A Filing Workflow for Multi-State Employers

State ACA reporting becomes much easier when it is treated as part of the same annual data process rather than five last-minute side projects.

A practical workflow looks like this:

1. Inventory employee and covered-individual residency. Start with where covered individuals lived during the reporting year. For most state individual mandate requirements, an individual’s state of residence drives the reporting obligation, although specific rules and filing triggers vary by state.
   
2. Determine who owns each filing. Fully insured? Confirm exactly what the carrier will file and furnish. Self-insured? Identify the obligations that stay with the employer. Multiemployer plan? Verify the plan sponsor’s role rather than assuming.
   
3. Validate your federal ACA data first. Forms 1094-C and 1095-C remain an important source for several state filings, so clean employee, dependent, coverage, TIN, and coding data gives you a much better starting point. Our year-end Forms 1094-C and 1095-C guide covers that preparation.
   
4. Map each jurisdiction’s file requirements and portal. California’s FTB system isn’t New Jersey’s filing process. D.C. doesn’t use the IRS AIR XML format. Massachusetts has entirely different forms. “We already created the federal file” does not necessarily mean “we can upload it everywhere.”
   
5. Calendar state deadlines independently. Federal dates are useful anchors, but state deadlines range from Massachusetts HIRD in December through D.C. in late April.
   
6. Save submission confirmations and handle corrections. When you upload something, verify that the state accepted it, retain the evidence, and make corresponding state corrections when federal coverage data changes.
   
7. Monitor state correspondence, too. IRS letters get attention because everyone recognizes the IRS logo. State notices deserve the same routing discipline.

For federal filing itself, see our guide to ACA e-filing through the IRS AIR system.

How Selerix Handles State ACA Filing

The simplest way to make state ACA reporting harder is to manage every jurisdiction as a completely separate project.

The better approach is to build it into the same compliance workflow.

Selerix ACA Compliance supports the reporting lifecycle from data review and form preparation through electronic filing, employee distribution, corrections, and state-specific requirements. The goal is to use the same validated coverage data to support federal and applicable state reporting rather than asking HR to reconstruct employee histories for every portal separately. 

Federal ACA Filing Isn’t the Finish Line

ACA reporting used to feel largely federal. But for multi-state employers, that is no longer a safe operating assumption.

The good news is that most state reporting regimes reuse at least some data you already collect for federal compliance. The bad news is that the forms, deadlines, furnishing requirements, filing methods, and ownership rules aren’t uniform.

So when AIR says Accepted, don’t automatically close the compliance folder. Check the map first. Put every applicable state deadline on the calendar. And make state acceptance and correction tracking part of the same process you use for federal ACA compliance.

One ACA Process. However Many States You Operate In.

Selerix helps employers manage federal and state ACA reporting in one coordinated workflow — from year-round data and 1095-C preparation through filing, furnishing, corrections, and state-specific requirements.

See how Selerix ACA Compliance can take the filing burden off your team.