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ACA & Open Enrollment Compliance: What to Close Out Before Year-End
Last updated: October 2026
Netchex payroll and HR software automates 1094-C and 1095-C filing and eligibility tracking, so the ACA forms you file each year come from the same data as your open enrollment elections and payroll.
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.
Open enrollment checklist
ACA compliance checklist (for applicable large employers)
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.
Faster open enrollment completion
Of compliance risk eliminated via automated ACA tracking and filing
Of employees report less financial stress from benefits like EWA and pay cards
Netchex collaborates directly with a client’s benefits brokers
Common questions
What is an ACA compliance checklist?
An ACA compliance checklist is the list of eligibility tracking, reporting, and filing steps an applicable large employer completes each year. It covers confirming eligibility, verifying 1095-C data, reconciling 1094-C totals, meeting filing deadlines, and archiving records, all centered on 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. For plan years starting in 2027, an applicable large employer’s lowest-cost self-only plan can’t cost an employee more than 10.22% of household income under the affordability safe harbors, a bit more room than 2026 allowed.
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. That timing is why it overlaps with year-end payroll and ACA prep, and why elections should be reconciled against payroll deductions before the first paycheck of the new plan year.
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 benefits themselves were administered correctly. Tracking eligibility and coverage offers accurately throughout the year prevents this at the source, instead of rebuilding records under deadline pressure when the forms are due.
What is the best payroll software for ACA form generation?
Netchex tracks employee eligibility and affordability through the year and automates 1094-C and 1095-C filing, so the forms come from the same payroll and benefits data. Netchex customers eliminate 65% of ACA compliance risk through this automated tracking and filing, rather than reconstructing hours and offers at deadline.
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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