Quick Answer: New Jersey 1095 filing requirements can apply when an employer provides minimum essential health coverage to New Jersey residents. Self-insured employers generally file the coverage information directly with the state, while fully insured employers normally rely on their insurance carrier. Multiemployer plan sponsors generally file for their plans. However, an employer may have to step in if the carrier or plan responsible for reporting fails to file. The federal Applicable Large Employer threshold does not determine whether New Jersey must receive coverage information.
Who Is Responsible for Filing 1095 Information With New Jersey?
New Jersey uses health coverage reporting to verify whether residents had minimum essential coverage under the state’s individual health insurance mandate. For employers, the most important question is usually who provides the coverage and who is responsible for reporting it, not simply how many employees the company has.
| Employer or Plan Arrangement | Who Generally Files With New Jersey? |
|---|---|
| Fully insured employer | Insurance carrier generally files |
| Self-insured employer | Employer generally files |
| Multiemployer health plan | Plan sponsor generally files |
| Out-of-state employer covering NJ residents | New Jersey reporting may still apply |
| Carrier or plan fails to file | Employer may have backup filing responsibility |
This distinction matters because a small self-insured employer may have a direct New Jersey reporting obligation even though it is not an Applicable Large Employer under federal ACA rules. A fully insured employer of the same size, by contrast, will generally rely on its carrier to report the coverage.
Do Fully Insured Employers Have to File 1095 Forms Themselves?
Usually not. When an employer provides coverage through a fully insured health plan, the insurance carrier generally submits the required coverage information to New Jersey.
That does not mean the employer should ignore the filing requirement. New Jersey advises employers to confirm that the carrier or multiemployer plan will make the required filing. If the entity responsible for reporting fails to do so, the employer may have to submit the necessary information.
The practical takeaway is simple: fully insured employers should verify that someone is filing, rather than assuming the state filing has automatically been handled.
What Do Self-Insured Employers Have to File?
Self-insured employers generally have the more direct responsibility because the employer itself provides the minimum essential coverage being reported.
The form used can depend on whether the employer is an Applicable Large Employer, or ALE, under federal rules:
| Employer Type | Typical New Jersey Reporting |
|---|---|
| Self-insured ALE | Form 1095-C with the required coverage information |
| Self-insured non-ALE | Form 1095-B or NJ-1095 |
| Fully insured employer | Carrier generally reports |
| Multiemployer plan participant | Plan sponsor generally reports |
For New Jersey purposes, a Form 1095-C containing only Parts I and II does not provide the coverage information the state needs. When a 1095-C is used for New Jersey coverage reporting, the form must include the information identifying who was actually covered, including the applicable Part III information.
Does the 50-Employee ALE Threshold Determine Who Must File?
No. This is one of the easiest New Jersey reporting rules to misunderstand.
Federal ALE status generally depends on the prior year’s calculation of full-time employees and full-time equivalents, with a threshold of 50. That classification affects federal ACA reporting, but it does not mean a New Jersey employer below the ALE threshold can automatically ignore state health coverage reporting.
A self-insured non-ALE can still have a direct New Jersey reporting obligation because it provides the coverage. A fully insured employer, including a smaller employer, generally relies on the insurance carrier instead.
For New Jersey reporting, plan funding is often more important than employer size.
Do Out-of-State Employers Have to Report Coverage for New Jersey Residents?
Potentially, yes. New Jersey’s reporting rules are not limited to companies headquartered in the state or employers that withhold New Jersey payroll taxes.
An out-of-state employer that provides minimum essential health coverage to New Jersey residents may still have a reporting obligation. Depending on the plan arrangement, the employer, insurance carrier, or another coverage provider may be responsible for sending the information to New Jersey.
Reporting can also involve qualifying part-year New Jersey residents. Employers with remote or multistate workers should therefore review where covered employees reside rather than relying only on the company’s headquarters or payroll location.
Which 1095 Forms Does New Jersey Accept?
New Jersey accepts several forms for reporting health coverage, including:
- NJ-1095
- Form 1095-B
- Form 1095-C with the required coverage information
The most important employer issue is the 1095-C distinction. A Form 1095-C with only Parts I and II does not satisfy New Jersey’s coverage-reporting requirement because it does not provide the individual coverage information needed by the state. When the 1095-C is used for state reporting, the required Part III coverage data must be included.
New Jersey does not require a separate Form 1094 solely for the state health coverage reporting requirement.
When Are New Jersey 1095 Forms Due?
New Jersey publishes reporting deadlines for each coverage year. For 2025 health coverage reported in 2026, forms were due to qualifying primary enrollees by March 2, 2026, and the coverage information was due to New Jersey by March 31, 2026.
Because those dates apply to a specific reporting year, employers should check the state’s current instructions before each filing cycle rather than assuming the deadlines will always fall on the same dates.
New Jersey requires these state coverage filings to be submitted electronically. Employers that are responsible for filing should confirm the current submission method and technical requirements before the applicable deadline.
What Should Employers Check Before Filing?
Employers can avoid much of the confusion by answering four questions before the reporting deadline:
- Is the health plan fully insured or self-insured? This usually determines whether the carrier or employer handles the filing.
- Who is responsible for submitting the forms? Fully insured employers should confirm that their carrier or multiemployer plan will file.
- Which New Jersey residents must be reported? Include applicable covered residents even when the employer is headquartered elsewhere.
- Does the form contain actual coverage information? A 1095-C that contains only offer-of-coverage information is not enough for the New Jersey requirement.
The federal ALE threshold should be considered when selecting and completing the appropriate federal form, but employers should not use it as the sole test for determining whether New Jersey coverage reporting applies.
Frequently Asked Questions About New Jersey 1095 Filing Requirements
No. The entity responsible for filing depends largely on how the health plan is funded. Fully insured employers generally rely on the insurance carrier, while self-insured employers generally have a direct reporting responsibility.
Potentially, yes. A self-insured employer can have a New Jersey reporting obligation even if it is not an Applicable Large Employer under federal ACA rules. A fully insured small employer normally relies on its insurance carrier to report the coverage.
Potentially, yes. New Jersey reporting can apply to coverage provided to New Jersey residents even when the employer is headquartered outside the state. Employers with multistate or remote workforces should review the residence of people covered by the plan.
No. When Form 1095-C is used to satisfy New Jersey’s coverage-reporting requirement, it must include the information showing who was actually covered. A form containing only Parts I and II does not provide the required individual coverage information.
A fully insured employer generally relies on the carrier to report coverage, but the employer can become responsible if the carrier or other entity expected to file does not meet the state requirement. Employers should confirm the filing arrangement before the deadline rather than discovering a missing filing afterward.
What Should New Jersey Employers Confirm Before the Next Filing Cycle?
Employers should first determine who is responsible for reporting the coverage. Fully insured employers should verify that their insurer or multiemployer plan will file as required, while self-insured employers should confirm the appropriate form and the covered New Jersey residents who must be reported. Employer size alone does not answer the question because a smaller self-insured employer can still have a direct New Jersey reporting obligation.
JS Benefits Group can help New Jersey employers review how health coverage reporting fits into employee benefits and HR administration.
