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New Electronic Filing Requirements for 2024

Posted on March 15th, 2023

On February 21, 2023, the Internal Revenue Service (IRS) published a final rule which changes the electronic filing requirements for Forms 1094-B, 1095-B, 1094-C, and 1095-C. These forms are used by insurance carriers and employers to report individuals covered under a plan that provides minimum essential coverage, and by applicable large employers (ALEs) who must report information pertaining to the Employer Mandate.

The new rule, effective for reporting submissions in 2024 and later years, changes the threshold for submitting these forms electronically. For reporting submissions occurring on or after January 1, 2024, electronic submissions will be required for any reporting entity submitting 10 or more returns (i.e., forms). The previous rules allowed for manual filing for reporting entities submitting up to 249 returns.

This change means most employers subject to the reporting will need to do so electronically; however, there will be an ability for some employers to seek a waiver from the electronic submission requirement in situations of an undue hardship. An undue hardship may occur in situations where the cost to file electronically exceeds the cost of filing manually.

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