COMPLIANCE ALERT – ACA Electronic Filing Requirements Changes for 2024
By: Birch

Since 2015, employers submitting at least 250, 1095 forms to the IRS have been required to file the forms electronically. Beginning in 2024 (for the 2023 ACA reporting year) employers filing at least 10 forms with the IRS will be required to file electronically. Employers must aggregate all forms to be submitted to the IRS, in order to determine whether they will exceed the new 10 form threshold. Forms to be considered are W-2s, 1095-Cs and the 1094-C.

Click here for new rule specifics.

New electronic filers will need to complete following steps in order to E-file with the IRS under the new threshold:

A. Apply for Your Organization’s Transmitter Control Code (TCC) for the IRS AIR System. The process for completing an application consists of the following steps:

  • Each Responsible Official (minimum of two required) and Contact (minimum of two required) within the firm or organization must complete the e-Services Secure Access Authentication process before the application can be submitted. Responsible Officials may also be Contacts on the application.
  • Complete all necessary pages on the ACA Application for TCC.
  • All Responsible Officials must sign the Application Submission Page with their e Services PIN to submit the application. Note: Responsible Officials may go to the Modify PIN tab to recover their e-Services PIN.
  • After the application is completed and submitted, the IRS will perform checks before assigning the firm or organization their TCC(s).
  • Once the application is completed, all Responsible Officials are authorized to access the application and modify the application as necessary.

These steps and the complete application process can be found in this IRS tutorial.

B. Once you have received your TCC Code, you will need to test with the IRS before you can e-file. Please note:

  • As a Transmitter or Issuer, you must use approved software to perform the Communications Test. You are only required to successfully complete the Communication Test once.
  • The process for completing the Communications Test can be found in this IRS tutorial.

For additional information, reach out to our team: