1 — 0926 Publ 5165 (PDF)

Section 1 Introduction

Publication 5165, Guide for Electronically Filing Affordable Care Act (ACA) Information Returns (AIR) for Software Developers and Transmitters (Processing Year [PY] 2026), outlines the communication procedures, transmission formats, business rules and validation procedures for information returns transmitted electronically through the AIR System. To develop software for use with the AIR System, Software Developers, Transmitters, and Issuers should use the guidelines provided in this publication along with the Extensible Markup Language (XML) Schemas published on IRS.gov. The procedures in this publication should be used when the following information returns are transmitted electronically for Tax Year (TY) 2015, TY2016, TY2017, TY2018, TY2019, TY2020, TY2021, TY2022, TY2024,TY2025, TY2026 in PY2027.

Returns

Form 1095-C, Employer-Provided Health Insurance Offer and Coverage

Note: This publication does not contain information or procedures for filing Form 1095-A.

The transmittal Forms 1094-B and 1094-C provide information about the Issuer of the ACA Information Returns and the Forms 1095-B and 1095-C provide information about the covered individuals. Generally, the Forms 1095B and 1095C will be submitted with their associated transmittals, Forms 1094-B and 1094-C; however, in certain circumstances, the Form 1094-C can be submitted alone. After these forms are processed by AIR, the status of each submission and a detailed acknowledgment is made available to each Transmitter.

The procedures in this publication should also be used in conjunction with the most current version of the following publications:

Publication 4557 - Safeguarding Taxpayer Data: A Guide for Your Business: The purpose of this

publication is to provide information on legal requirements to safeguard taxpayer data. The target audience is non-government businesses involved in the preparation and filing of income tax returns.

Publication 5164 - Test Package for Electronic Filers of Affordable Care Act (ACA) Information Returns

(AIR): This publication contains general and program specific testing information for use in completing the ACA Assurance Testing System (AATS) process for business submissions. AATS is a process to test software and electronic transmissions prior to accepting Software Developers, Transmitters, and Issuers into the AIR program.

Publication 5258 - Affordable Care Act Information Returns (AIR) Submission Composition and

Reference Guide. Guidance to Internal Revenue Service (IRS) external partners (Software Developers, Transmitters, and Issuers) with composing submissions and transmission files that are sent to IRS for processing. Description of the interaction between AIR and the Transmitter through the Information Submission Services (ISS) User Interface (UI) and Application to Application (A2A) channels.

Publication 5308 - Automated Enrollment for ACA Providers IRS developed this guide for the

AIR System authorized contacts who want to use Automated Enrollment (AE) to enroll A2A Client Application Systems into the IRS Application to Application (A2A) channel. The Automated Enrollment

Guide for Electronically Filing ACA Information Returns for Software Developers and Transmitters 2

Introduction

(AE) application provides authorized, delegated users the ability to enroll and update the A2A Client Application System ID (ASID) using the Integrated Enterprise Portal (IEP).

AIR publications and guides are located on the Affordable Care Act Information Returns (AIR) page.

1.1 | Purpose

The purpose of this publication is to provide the specifications to electronically file the ACA Information Returns (Forms 1094/1095-B and 1094/1095-C) with IRS.

Forms 1094/1095-B and 1094/1095-C are information returns under Section 6011(e)(2)(A) of the Internal Revenue Code which provides that any person, including a corporation, partnership, individual, estate, or trust, who is required to file 10 or more information returns, must file such returns electronically. 10 or more Information Return requirement applies separately for each type of return and separately to each type of corrected return.

Treas. Reg. (TD 9972) reduced the threshold from 250 to10 and requires corrected information returns to be filed in the same manner as original information returns.

Note: All filers are encouraged to file the ACA Information Returns electronically even if they file less than 10 information returns. Final regulations were issued June 27, 2023, by the Department of the Treasury and the Internal Revenue Service. These regulations reduced the 250-Return threshold to generally require electronic filing by filers of 10 or more returns in a calendar year beginning in Tax Year 2023, Processing Year 2024.

All filing requirements apply individually to each reporting entity as defined by its separate Tax Identification Number (TIN). Issuers should retain a copy of information returns (or have the ability to reconstruct the data) for at least three years from the reporting due date.

1.2 | Communications

IRS worked in partnership with many AIR stakeholders to develop the information contained within this publication. The ACA Information Return (AIR) Help Desk has been designated as the first point of contact for electronic filing issues Software Developers, Transmitters and Issuers should contact the AIR Help Desk toll free at 1-866-937-4130, for domestic calls, or 470-769-5100 (not toll-free) for international calls. The AIR Help Desk provides assistance in the following areas:

ACA Application for Transmitter Control Code (TCC)
ACA Assurance Testing System (AATS) and Communication Testing
Business Rules and Error Code Resolution

For inquiries regarding issues with the AIR System and the new development of the forms related to the ACA Program please contact AIR Help Desk - 1-866-937-4130

Guide for Electronically Filing ACA Information Returns for Software Developers and Transmitters 3

Introduction

1.2.1 | AIR Web Site

For information regarding the AIR System and electronic filing Affordable Care Act Information Returns go to Affordable Care Act Information Returns (AIR) webpage. The AIR page provides:

Online ACA Information Returns (AIR) System (Production and Testing) Status
ACA Information Returns (AIR) Program Overview
Affordable Care Act Assurance Testing System (AATS) Information
Resources to ACA Information Returns (AIR) Publications, Schemas, Business Rules and much more

If you encounter an issue or limitation that prevents an ACA Information Return from being submitted electronically through AIR, and the solution is not posted on the Affordable Care Act Information Return (AIR) webpage, please contact the AIR Help Desk. The Service will then work on making the appropriate corrections or assisting with the issue or limitation. Until corrections can be implemented, AIR may develop “workarounds" which are temporary changes to allow the return to be transmitted electronically. Workarounds will be posted by Tax Year (TY) and linked to the Schema and Business Rules page under the “Known Issues.”

AIR uses QuickAlerts, an IRS e-mail and SMS service, to disseminate information quickly regarding AIR issues to subscribers. This service keeps tax professionals up to date on AIR issues throughout the year, with emphasis on issues during the filing season. After subscribing, customers will receive “round the clock” communications issues such as electronic specifications and system information needed for Software Developers and Transmitters to transmit the Forms 1094/1095-B and 1094/1095-C to IRS. New subscribers may sign up through the "subscription page" link located on the QuickAlerts "More" e-file Benefits for Tax Professionals page.

1.3 | Filing ACA Returns through a Third-Party Transmitter

If you do not have an in-house programmer familiar with XML or software that is certified to support the ACA forms that you plan to file, you can file through a Third-Party Transmitter.

Only those persons listed as an Authorized User on the ACA Application for TCC qualify to receive information about a Receipt ID associated with a TCC listed on that application.

If your Third-Party Transmitter needs technical assistance regarding a Receipt ID associated with records that were submitted on behalf of your organization, they should contact the AIR Help Desk at 1-866-937-4130.

1.3.1 | When filing through a Third-Party Transmitter obtain the following for each submission filed on your behalf (1094-B or C and accompanying 1095 records):

A copy of all electronic records within each submission, along with the Receipt ID for the transmission in

which they were filed.

The transmission Status that is returned when processing is complete (Accepted, Accepted With Errors,

Partially Accepted, Rejected).

The Error Data File if the status is anything other than “Accepted.” The Error Data File will provide a

detailed list of errors, such as TIN Validation and Business Rule errors.

Note: The items cited above are critical to your ability to make corrections should your Third-party Transmitter go out of business or be otherwise unavailable to file corrections on your behalf.

Guide for Electronically Filing ACA Information Returns for Software Developers and Transmitters 4

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