Under Section 6056 of the code, employers must provide information to the IRS and employees about coverage that employers offer to employees. Section 6055 requires employers that offer self-insured plans and insurers to report to the IRS information on individuals enrolled in coverage, including Social Security numbers for employees and their dependents. However, the final instructions for forms 1094-B and 1095-B clarify that health insurers may provide taxpayer identification numbers for covered individuals who do not have Social Security numbers.. The information reporting requirements generally apply to large employers under the ACA, i.e., employers with at least 50 full-time equivalent employees (100 or more for 2015).

Employers must collect information about the coverage period beginning Jan. 1, 2015—the effective date of the employer mandate. Information returns will be filed for the first time in 2016. The final regulations apply the same filing schedule used for Form W-2 and Form 1099 to the section 6055 and 6056 reporting. The rules provide that section 6055 and 6056 returns must be filed annually with the IRS by Feb. 28, or by March 31 if filing electronically, of the year immediately following the calendar year to which the return relates. Statements to employees must be provided annually by Jan. 31.