IRS Reporting in 2024

Electronic Filing Requirements

The Internal Revenue Service (IRS) issued guidance in February relating to new reporting requirements in 2024. Filings for the calendar year 2023, that are completed in 2024, will be subject to the new requirements.

These new rules contain significant changes that employers must be ready for heading into the new year.

The released guidance requires any employer that files more than 10 forms to the IRS in aggregate, or in total, must be filed electronically. These IRS annual returns include, but are not limited to IRS forms:

In effect, almost all employers will need to begin transmitting their IRS forms electronically. For example, if an employer must file eight (8) W-2s, four (4) 1099s, and six (6) 1095s, that would be 18 forms in total and the employer is subject to filing all of them electronically, keeping in mind each forms’ related deadlines.

This change will impact smaller employers that have filed paper forms to the IRS in the past, particularly those offering level-funded, self-funded or any other alternative funding methods. You should check with your carrier, Third Party Administrator (TPA), or Administrative Services Only (ASO) vendor to determine if they will be performing this filing and if they will charge for completing these annual returns.

For filings completed prior to, or in 2023, which are for calendar years 2022 and earlier, the threshold for filing the 1095s electronically was determined if the employer released 250 or more W-2s. The aggregation rule of all the related employee tax filing documents was not in effect previously.

The IRS guidance release is available online at

Also, remember that some states may require an annual filing, in addition to the IRS annual returns. Currently, California, Massachusetts, New Jersey, Rhode Island, and the District of Columbia have mandates for insurance coverage and require annual filings. While Vermont has an insurance mandate, they currently do not have a reporting requirement for employers.

Reach out to your BenefitMall Value Added Products Sales Executive if you need assistance with solutions for your clients to adhere to these new requirements.

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