Employee Benefits News
Affordable Care Act: 2026 Compliance Checklist
The Affordable Care Act (ACA) made widespread reforms to health plan coverage when it was enacted in 2010. Since then, changes have been made to various ACA requirements for employer-sponsored health coverage. These changes include annual cost-of-living increases to certain ACA dollar limits, adjustments to ACA reporting requirements, and updates to preventive care coverage guidelines.
Changes to some ACA requirements will take effect in 2026 for employers sponsoring group health plans. For example, the affordability percentage under the ACA’s employer mandate rules for applicable large employers (ALEs) will increase significantly for plan years beginning in 2026, which may provide ALEs with more flexibility when setting their employee contribution rates.
To prepare for 2026, employers can use this checklist to review these ACA requirements and develop a compliance strategy. Employers should ensure that their health plan documents, including the Summary of Benefits and Coverage (SBC), are updated to reflect any new plan limits. Employers should also ensure that up-to-date information is communicated to employees at open enrollment time.
Additional Links and Resources
- IRS Rev. Proc. 2025-25 indexed the ACA’s affordability percentage for plan years beginning in 2026.
- IRS Rev. Proc. 2025-26 modified the penalty amounts under the ACA’s employer mandate for 2026.
- A final rule established the cost-sharing limits for 2026 plan years.
Employers Should Start Preparing for 2026 RxDC Reporting
Group health plans and health insurance issuers must annually submit detailed information on prescription drug and healthcare spending to the Centers for Medicare and Medicaid Services (CMS). This reporting is referred to as the prescription drug data collection (RxDC report). The next RxDC report is due by June 1, 2026, covering data for 2025.
The RxDC report is comprised of several files, including those that require specific plan-level information, such as plan year beginning and end dates and enrollment and premium data. It also includes files that require detailed information about medical and pharmacy benefits. There are no major changes to the reporting instructions from the RxDC reporting that was completed in 2025.
Most employers contract with third parties, such as issuers, third-party administrators (TPAs), and pharmacy benefit managers (PBMs), to submit RxDC reports on behalf of their health plans. Employers may work with multiple third parties to complete the RxDC report for their health plans. For example, a self-insured employer may use both its TPA and PBM to submit different portions of the RxDC report. A health plan’s submission is considered complete if CMS receives all required files, regardless of who submits them.
ACA Reporting Requirements for 2026
The Affordable Care Act (ACA) created reporting requirements under Internal Revenue Code (Code) Sections 6055 and 6056.
- Under Section 6055, self-insuring employers and other parties that provide minimum essential health coverage must report information on this coverage to the IRS and to covered individuals upon request.
- Under Section 6056, applicable large employers (generally, those with 50 or more full-time employees) are required to report information to the IRS, and to their full-time employees upon request, about their compliance with the employer-shared responsibility (pay or play) rules and the health coverage they have (or have not) offered.
This checklist outlines key steps for employers to comply with the ACA’s reporting requirements. Keep in mind that a growing number of states have enacted their own health coverage reporting requirements. Employers need to comply with the federal ACA reporting requirements and any applicable state reporting requirements.
Use this checklist as a guide when reviewing your company’s compliance with the ACA’s reporting requirements in 2026.
HR on Mic Podcast
Our HR on Mic podcast is your source for thoughtful discussions about HR, Compliance, Benefits, and Treating People Right.
Hosted by Corbin Granger, Towne Benefits Senior Vice President of Compliance, and Barbara Jennings, Towne Benefits Human Resources Consultant, HR on Mic provides helpful information on human resources and compliance topics in short, easy-to-listen-to segments.
Our latest episode covers a range of employee benefits topics of interest to employers, including tax-deductible overtime pay, pre-tax dependent care accounts, and tuition reimbursement.