Earlier this year IRS established that employers with an aggregate of 10 or more information returns must submit those returns electronically. This rule is applicable for 1094/1095 B & C returns required under the Affordable Care Act (ACA), which are due April 1. Employee copies must be disbursed by March 4.
Before the new rule, employers could have up to 250 information returns before being subject to an e-filing requirement. Employers who will be required to file electronically should prepare now by establishing how they will meet the compliance requirements. Along with the 1094/1095 B and C series forms an entity should count Forms 1099, employment tax returns and excise tax returns in their aggregate returns total.
Within the final ruling is a provision to waive the requirement if it causes undue economic hardship to the issuer. Entities may provide two cost estimates from third parties for software, software upgrades or programming proving that preparing to e-file would impose economic hardship.