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Benefits Administration

ACA & Open Enrollment Compliance: What to Close Out Before Year-End

ACA & Open Enrollment Compliance: What to Close Out Before Year-End

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ACA & Open Enrollment

ACA & Open Enrollment Compliance: What to Close Out Before Year-End

Open enrollment and ACA reporting land in the same window as everything else at year-end. Here’s how to keep them from colliding.

Why open enrollment and ACA compliance belong on the same checklist

Benefits elections made during Q4 open enrollment directly feed the ACA reporting employers file a few months later on Form 1095-C. A messy open enrollment process doesn’t just confuse employees, it creates bad data that shows up as a compliance problem in March. Treating the two as one connected process, not separate projects, is what actually prevents both headaches.

Confirmed for 2027

ACA affordability percentage rises to 10.22%

Up from 9.96% in 2026, per IRS Revenue Procedure 2026-26 (published July 21, 2026), the highest affordability percentage since the ACA’s inception. For plan years starting in 2027, your lowest-cost self-only plan can’t cost an employee more than 10.22% of household income under the affordability safe harbors, which is a bit more room than 2026 gave you when pricing that plan.

Open enrollment checklist

Confirm plan documents and rate changes are finalized before enrollment opens
Communicate the enrollment window clearly and repeatedly (email, in-platform, physical postings if applicable)
Offer a self-service enrollment option so elections are captured electronically, not on paper
Flag employees who haven’t completed enrollment with automated reminders before the window closes
Reconcile completed elections against payroll deductions before the first paycheck of the new plan year
Confirm COBRA and qualifying life event processes are documented and ready for the year ahead

ACA compliance checklist (for applicable large employers)

Confirm employee eligibility tracking is current for the full reporting year (measurement periods, hours worked)
Verify 1095-C data (coverage offered, affordability against the 2027 10.22% threshold, safe harbor codes) is accurate for every eligible employee
Reconcile 1094-C transmittal totals against your actual employee count
Confirm filing deadlines: 1095-C to employees typically due early-to-mid March, IRS filing shortly after (verify current-year dates, since they shift slightly year to year)
Archive the year’s ACA documentation per your retention policy

What automated ACA tracking actually removes from your plate

Most ACA compliance failures aren’t willful, they’re the result of tracking eligibility and affordability by hand across a workforce that moves between full-time and part-time status throughout the year. Automated tracking catches the changes as they happen instead of reconstructing them under deadline pressure, which is a large part of why Netchex customers eliminate 65% of that compliance risk through automated 1094-C/1095-C filing and tracking.

50%

Faster open enrollment completion

65%

Of compliance risk eliminated via automated ACA tracking and filing

89%

Of employees report less financial stress from benefits like EWA and pay cards

Direct Access

Netchex collaborates directly with a client’s benefits brokers

FAQ

Common questions

What is an ACA compliance checklist?

A list of the eligibility tracking, reporting, and filing steps applicable large employers need to complete each year to meet Affordable Care Act reporting requirements, primarily Forms 1094-C and 1095-C.

What is the 2027 ACA affordability percentage?

10.22%, confirmed by the IRS in Revenue Procedure 2026-26, up from 9.96% in 2026. Your lowest-cost self-only plan can’t cost an employee more than 10.22% of household income under the affordability safe harbors for plan years starting in 2027.

When is open enrollment usually held?

Most employers run open enrollment in the fall, commonly October or November, for benefits that take effect January 1, which is also why it overlaps with year-end payroll and ACA prep.

What happens if ACA reporting has errors?

Incorrect 1095-C data can trigger IRS penalty notices for affordability or coverage-offer discrepancies, even when the underlying benefits were administered correctly. Accurate tracking throughout the year prevents this at the source.

This page is general information, not legal or tax advice. ACA deadlines can shift slightly year to year, confirm current dates before relying on them.

Further reading: the Year-End Payroll Checklist and Reducing Benefits Confusion During Open Enrollment.

Make open enrollment and ACA reporting one connected process

See how Netchex automates eligibility tracking, enrollment, and ACA filing on one platform.

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