As a reminder, if an employer has at least one employee who resides primarily in New Jersey for at least 15 days in any month, the employer is subject to file Form(s) 1095 with the New Jersey Division of Taxation in the subsequent year annually. The current 2025 tax year's filing is due on March 31, 2026, with copies to be distributed to primary enrollees by March 2, 2026. To meet NJ's reporting requirements, employers can provide copies of Forms 1095-C (or B) prepared for the ACA employer mandate and individual mandate provisions.
For fully insured plans, if their insurers are filing and distributing their New Jersey residents' Form(s) 1095-B, then the employers are not required to file or distribute the forms. However, employers are encouraged to discuss and confirm with their insurers that the insurers are completing state reporting in a timely manner.
For self-insured plans, employers are responsible for timely filing completed Forms 1095-C (or B) with the state and distributing them to participants. Note that employers who elect to provide annual coverage statements to enrollees upon request only (as permitted for federal reporting purposes beginning in 2025) are nonetheless required to automatically distribute statements to New Jersey residents in compliance with the state reporting law.
The main objective of this reporting is for New Jersey to enforce its individual mandate requirement by verifying that each resident had health coverage in the prior year.
For more information, visit the New Jersey Shared Responsibility Requirement web page.