The 2025 ACA Compliance Checklist for CFOs: What You Need to Do Now to Avoid Fines Later

“Our CFO said we were compliant—until we got hit with a $78,000 penalty.”
That’s what the HR director of a 150-person manufacturing firm said after discovering that one missing document triggered a chain reaction with the IRS. The mistake wasn’t malice. It was complexity.

The Affordable Care Act (ACA) is no longer new—but for CFOs, the compliance challenges are growing more sophisticated, not less. With updated enforcement protocols, stricter documentation rules, and tighter deadlines, 2025 is shaping up to be a year of heightened scrutiny.

This comprehensive ACA compliance checklist will help you, the CFO, audit your current processes, reduce your exposure, and navigate the legal terrain without sleepless nights or costly surprises.

Why ACA Compliance Still Trips Up Smart Companies

ACA compliance isn’t just an HR issue—it’s a financial liability that lands squarely on your desk as the CFO.

Why?

• Penalties are increasing. In 2025, failing to offer Minimum Essential Coverage (MEC) can cost up to $2,970 per employee, per year.

• Data reporting requirements are tightening. Errors in 1095-C/1094-C filings trigger audits and fines.

• IRS enforcement is escalating. The agency is actively closing gaps in employer-provided data vs. individual tax returns.

A few missed checkboxes can result in six-figure penalties. But with the right checklist, you can confidently prevent that.

The 2025 ACA Compliance Checklist for CFOs

Use this structured audit framework to review your ACA obligations and ensure airtight compliance.

1. Determine ALE Status for 2025

If you employed 50+ full-time or full-time equivalent employees on average during 2024, you are classified as an Applicable Large Employer (ALE).

Action Step: Confirm headcount using IRS methods. Don’t rely on a single month—use a 12-month look-back period.

2. Offer MEC to 95% of Full-Time Employees

ALEs must offer Minimum Essential Coverage (MEC) to 95% of full-time employees and dependents to avoid the 4980H(a) penalty.

Tip: Offering the wrong plan—even with good intentions—can still trigger fines. MEC must meet IRS definition, not just internal standards.

3. Ensure Coverage is Affordable

For 2025, employee contributions for self-only coverage must not exceed 8.39% of household income.

Action Step: Choose one of the IRS safe harbors (W-2, Rate of Pay, or Federal Poverty Line) to calculate affordability.

4. Confirm Minimum Value (MV)

The plan must cover at least 60% of the total allowed cost of benefits expected to be incurred.

Tool: Request an actuarial value certificate from your broker or carrier.

5. Distribute 1095-C to Employees

Every full-time employee (and anyone who was offered coverage) must receive Form 1095-C by March 3, 2025.

Note: This deadline is earlier if you are sending paper forms.

6. File 1094-C and 1095-C with the IRS

Forms must be submitted electronically to the IRS by April 1, 2025 (or February 28 if filing by paper and under 250 forms).

Warning: Late or incorrect filings may incur $310 per form penalties.

7. Verify Data Before You Submit

Most ACA penalties are issued not because coverage wasn’t offered—but because the data was wrong or incomplete.

Checklist: Confirm full-time status, employment dates, dependent coverage, and affordability calculations.

8. Maintain Records for 3+ Years

Audit defense starts with documentation. Keep:

• Plan summaries

• Enrollment records

• Affordability calculations

• Safe harbor election statements

• Communications with brokers

CFO Pitfalls to Avoid in 2025

Even seasoned finance leaders fall into these traps:

Relying Solely on Your Broker

Brokers aren’t always ACA experts. Many focus on product selection—not compliance. Treat ACA as a financial risk, not a benefits afterthought.

Missing Data from Part-Time or Seasonal Staff

Even if not eligible for benefits, all employees must be included in FTE calculations. Incomplete data equals compliance gaps.

Using Legacy Payroll Systems That Don’t Track ACA

Outdated systems often lack integrated ACA tracking. Ensure your technology can:

• Track FTE status

• Monitor affordability

• Auto-populate 1095-C data fields

Real-World Example: The Cost of a Missed Threshold

In 2023, a regional contractor miscalculated its ALE status after onboarding several seasonal employees. Thinking they were below the 50 FTE threshold, they didn’t file 1095-Cs.

Six months later, they were hit with $94,000 in 4980H(a) penalties.

The fix? A retroactive compliance strategy—filing corrected forms, restructuring their MEC offering, and implementing real-time tracking. But the cost was painful.

Strategic Tip: Don’t Just “Comply”—Use ACA to Optimize Benefits Strategy

ACA doesn’t have to be just another regulation—it can be a strategic opportunity.

For example:

• Offering MEC plans can help reduce payroll taxes under Section 125

• Preventive care structures can improve employee wellness and retention

• Optimized ACA reporting can align with DEI and ESG goals

CFOs who leverage compliance strategically don’t just stay out of trouble—they create financial and cultural upside.

Final Thought + Call to Action

ACA compliance isn’t just about avoiding penalties—it’s about protecting your business and creating long-term operational clarity.

CFOs who get ahead of ACA requirements not only avoid costly fines but also position themselves as strategic leaders who understand the intersection of finance, compliance, and workforce well-being.

Want a second set of eyes on your 2025 ACA readiness?
Schedule a free consultation today and uncover missed opportunities, hidden risks, and powerful tax-saving strategies built into the law.