If your organization provided health coverage to a New Jersey resident during the calendar year, New Jersey ACA reporting requires you to send a 1095 form (federal 1095-A, 1095-B, 1095-C, or the state’s NJ-1095) to the Division of Taxation by March 31, and to deliver a copy to each primary enrollee by March 2. Miss either step and the state can assess up to $50 per missing form, capped at $50,000, and your employees’ state tax returns can get snarled in the process.
Who Has to File
The obligation reaches any entity that covered even one New Jersey resident: insurance carriers, employers, government agencies, health insurance exchanges, and multiemployer plan sponsors. It does not matter whether you withhold New Jersey payroll taxes. An out-of-state employer with a single New Jersey resident on the plan has to file.1State of New Jersey. NJ Health Insurance Mandate – Employers and Coverage Providers
Part-year residents count too. New Jersey treats someone as a resident for any month in which they were domiciled in the state for at least 15 days. An employee who moved to New Jersey in October gets reported for October, November, and December.1State of New Jersey. NJ Health Insurance Mandate – Employers and Coverage Providers
Which Form to Use
The right form depends on how you provide coverage and how large you are. Picking the wrong one is a common reason filings get rejected.
Fully Insured Employers
If you buy group coverage through a carrier, the carrier typically files a 1095-B or NJ-1095 for each covered member, regardless of whether you are an Applicable Large Employer. If the carrier fails to file, the obligation reverts to you. Confirm with your insurer each year that they will handle the New Jersey submission, because the state will come looking for you if the forms never arrive.1State of New Jersey. NJ Health Insurance Mandate – Employers and Coverage Providers
Self-Insured ALEs
A self-insured Applicable Large Employer files a fully completed 1095-C for every person who was a full-time employee for at least one month, plus any employee enrolled in the self-insured plan. For non-employees covered under the plan (retirees, non-employee directors, COBRA beneficiaries carried over from a prior year), the ALE can file a 1095-B, an NJ-1095, or a 1095-C using Code 1G in Part II.1State of New Jersey. NJ Health Insurance Mandate – Employers and Coverage Providers
Self-Insured Non-ALEs
Smaller self-insured employers file a 1095-B or NJ-1095 for each covered employee. They do not need to complete the full 1095-C with its offer-of-coverage codes.1State of New Jersey. NJ Health Insurance Mandate – Employers and Coverage Providers
Multiemployer Plans
For employers in a multiemployer plan, the plan sponsor (usually a board of trustees) handles filing. Fully insured arrangements use 1095-B or NJ-1095 forms for enrolled individuals; self-insured arrangements place the same responsibility on the sponsor for each covered employee.1State of New Jersey. NJ Health Insurance Mandate – Employers and Coverage Providers
Accepted Forms
New Jersey accepts fully completed federal 1095-A, 1095-B, and 1095-C forms. It also accepts 1095-C forms with only Parts I and III completed. As a substitute for either the 1095-B or 1095-C, filers may use the NJ-1095, a state form available on the Division of Taxation’s website with year-specific instructions.1State of New Jersey. NJ Health Insurance Mandate – Employers and Coverage Providers
Every form must carry the primary enrollee’s full legal name, mailing address, and Social Security Number. Where no SSN is available, a date of birth works as an alternative identifier. Each covered dependent needs the same identifying information, and the form has to show a month-by-month breakdown of which months each person was enrolled. Mismatched names or Social Security Numbers are one of the fastest routes to a reconciliation failure on the state’s end, which spills over onto the employee’s tax return.
How to Transmit the Forms
Submission is electronic. The method depends on volume.
50 or More Forms: MFT (Axway)
Filers at or above 50 forms use the MFT SecureTransport (Axway) system. If you already have MFT credentials for other New Jersey tax filings, use the same account and start the filename with “NJHIM.” Files must be in XML (matching the federal filing structure) or in a pipe-delimited flat text format, and each file must stay under 12 MB. Larger submissions can be split across multiple files. Zipped files are not accepted.1State of New Jersey. NJ Health Insurance Mandate – Employers and Coverage Providers
One MFT account can submit for multiple companies, which helps payroll providers and third-party administrators filing on behalf of several clients. A confirmation receipt goes to the email tied to the MFT account after a successful upload. Keep it. That receipt is your proof of timely filing.
Fewer Than 50 Forms: NJ-1095 Portal
Coverage providers with fewer than 50 forms file the NJ-1095 through the Division of Taxation’s online portal rather than through MFT. No Axway credentials are required, which makes it the simpler path for small self-insured employers and other filers with limited New Jersey enrollment.1State of New Jersey. NJ Health Insurance Mandate – Employers and Coverage Providers
Deadlines for the 2026 Filing Season
Two dates control the 2026 cycle (for 2025 coverage):
- March 2, 2026: Distribute a 1095 form to each primary enrollee who was a New Jersey resident and received coverage during any part of 2025.
- March 31, 2026: Transmit all 1095 forms to the New Jersey Division of Taxation.
Distribution comes first because residents need the forms to prepare their state returns. Delivery can be by mail or, where the recipient has consented, by secure electronic means. The March 31 transmission deadline is firm, though New Jersey has historically aligned with federal extensions when the IRS pushes back its own ACA reporting dates.1State of New Jersey. NJ Health Insurance Mandate – Employers and Coverage Providers
Fixing Errors After You File
If you catch errors after your original submission is accepted, or if you file a correction with the IRS, you must send the correction file to New Jersey as well. Corrections run through the same MFT (Axway) system and are subject to the same 12 MB per-file limit.1State of New Jersey. NJ Health Insurance Mandate – Employers and Coverage Providers
Where the Division finds significant discrepancies between your filings and what residents report on their individual returns, it contacts the filer. Fixing mismatched Social Security Numbers or coverage months early spares your organization the back-and-forth and your employees the surprise tax assessments.
Penalties and Downstream Effects
Failing to file costs $50 per individual whose form is missing, up to $50,000. The state can assess the penalty against the carrier, the employer, or both. The direct fine is often the smaller problem. When forms do not arrive, resident employees’ NJ-1040 returns can be rejected, they can be incorrectly assessed a Shared Responsibility Payment, and refunds get delayed. The employee complaints and administrative work that follow typically outweigh the dollar penalty.
What Counts as Minimum Essential Coverage
Reporting entities get asked which plans trigger the obligation. New Jersey follows the federal definition of Minimum Essential Coverage as it existed on December 15, 2017, with a few state clarifications. Qualifying coverage includes:2State of New Jersey. NJ Shared Responsibility Requirement – Get Info
- Employer-sponsored group coverage, including COBRA continuation.
- Individual market plans purchased through the Marketplace or directly from an insurer, including catastrophic plans.
- Medicare Part A (Part B alone does not count), Medicaid, CHIP, TRICARE, and VA health coverage.
- Dependent coverage on a parent’s plan, which New Jersey allows up to January 1 of the year after the dependent turns 26.
Vision-only or dental-only plans, workers’ compensation, disease-specific policies, and discount plans do not qualify, so you do not file 1095 forms for them.2State of New Jersey. NJ Shared Responsibility Requirement – Get Info
Whether an individual employee ultimately owes a Shared Responsibility Payment or qualifies for an exemption is handled on their own return. Your reporting duty is the same either way: file an accurate 1095 for every covered New Jersey resident, on time, through the right channel.