2026 ACA 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.
Plan Design Changes
The following plan design requirements will change for 2026:
- Limits on cost sharing for essential health benefits;
- Coverage affordability percentage under the employer mandate rules; and
- First-dollar coverage for recommended preventive care items and services.
ACA Reporting Deadlines
Individual statements: Employers must post a website notice by March 2, 2026, stating employees may receive a statement upon request (alternatively, employers may automatically provide statements to employees by this date); and
ACA returns: The deadline for employers to electronically file their 2025 ACA returns with the IRS is March 31, 2026.
View 2026 ACA Compliance Checklist
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.
- Complying with the ACA's Pay or Play Rules for 2026 - Checklist
Contact SSG for more information.
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