Recap: The IRS AIR System Electronic Transmittal for ACA Reporting

November 23, 2015

As the deadlines for the first year of ACA mandatory reporting to the IRS quickly approach, organizations should have already identified their ACA reporting obligations under IRC 6055 and/or 6056. No matter your organization’s specific obligations for the ACA under those codes, one thing remains consistent: The AIR System electronic transmittal to the IRS.

The electronic transmittal to the IRS via the  AIR System remains the hardest piece of this new tax information reporting obligation, according to many tax and compliance professionals already familiar with tax information reporting and the existing IRS FIRE System used for other 10-series tax forms. In fact, many vendors offering ACA reporting solutions have announced that they won’t be able to help organizations with this required IRS transmittal.

For more information about the complexities around building an AIR System electronic transmittal, please see our recent posts:

Lessons Learned from ACA Beta Tax Year 2014

A difficult part of this new mandatory reporting tax obligation is ensuring the fields of the required 1094/1095 forms are accurate and filed on time using the correct transmittal feed to the IRS AIR system. This is critical to avoid costly fines and penalties and alleviate damage to your reputation, not to mention prevent disruption to your business and dissatisfaction amongst your employees.

As an organization with 30 years dedicated to tax information reporting, we wanted to share our lessons and insights learned from the initial beta year.

Moving Forward into Tax Year 2015 for ACA Mandatory Reporting

There are also a multitude of technical considerations the IRS has recently published that are worth sharing for any organization still considering an internally built solution or who are unsure about how they will respond to these new requirement. For instance:

  • In the Affordable Car Act Assurance Testing (AATS) environment, the error message file will not be included for a “Rejected” status in Tax Year 2014.
  • Note: The error message file will be included in AATS Tax Year 2015.
  • For “Rejected” status, you can contact the AIR mailbox at the IRS. You will need to provide a Receipt ID with your request.
  • For “Accepted With Errors” status, review the scenario, correct the data, and resubmit.
  • For “Accepted” status, contact the IRS Help Desk at 866-937-4130 to be moved from Test to Production.
  • Verify the correct SOAP version is being used; currently, it should be SOAP 1.1.
  • Once you have passed AATS, you must use the Production “P” Transmitter Control Code (TCC) for issuer or transmitter.
  • When logging onto the IRS Registered User Portal (RUP), make sure you are selecting the correct test or production environment.

These are significant points for Tax Year 2015 ACA mandatory reporting that you need to know how to handle in order to process your transmittal to IRS properly in order to avoid costly delays and potential exposure to penalties.

Whether you are compiling your information to submit in-house or you are using a third-party vendor, it is important to note that not everyone is equipped to handle the necessary transmittal to the IRS. Do you have a comprehensive plan and the capabilities in place that account for this crucial and mandatory reporting steps?

Have questions about the technical components of transmitting to the IRS? Connect with one of our experts at Sovos. We’ll be happy to answer your questions and provide you useful information about solutions available to ensure compliant and accurate, timely transmittals to the IRS.

Sign up for Email Updates

Stay up to date with the latest tax and compliance updates that may impact your business.



Sovos is a leading global provider of software that safeguards businesses from the burden and risk of modern transactional taxes. As VAT and sales and use tax go digital, businesses face increased risks, costs and complexity. The Sovos Intelligent Compliance Cloud is the first complete solution for modern tax, giving businesses a global solution for tax determination, e-invoicing compliance and tax reporting. Sovos supports more than 7,000 customers, including half of the Fortune 500, and integrates with a wide variety of business applications. The company has offices throughout North America, Latin America and Europe. Sovos is owned by London-based Hg. For more information visit and follow us on LinkedIn and Twitter.
Share This Post

LATAM VAT & Fiscal Reporting
May 20, 2020
Sovos Acquires Taxweb, Extends Tax Determination Capabilities in World’s Most Challenging Compliance Landscape

Earlier this month Sovos announced its second acquisition of 2020, completing our solution for Brazil with an unparalleled offering that solves tax compliance in the place where it is most challenging to do so.  Too many companies doing business in Brazil have been burdened by managing multiple point solutions for continuous transaction controls (CTCs), tax […]

Tax Compliance
August 7, 2020
GAO Urges IRS to Overhaul 1099 Reporting for the Gig

A couple of weeks ago, the Government Accountability Office (GAO) released a report to the Senate Finance Committee describing the issues the IRS faces in enforcing income tax compliance for gig economy workers. The report highlighted long-standing issues the government has been grappling with in receiving tax information necessary to enforce compliance along with specific […]

EMEA VAT & Fiscal Reporting
August 4, 2020
New VAT Rules for Online Marketplaces and Imports of Goods into the UK

The United Kingdom’s HMRC has issued new guidance on the VAT treatment of cross-border sales of goods and online marketplaces beginning 1 January 2021, following the end of the transition period. Cross-Border Sales under £135 New rules will apply when a business sells goods for £135 or less to a UK customer and the goods […]

EMEA VAT & Fiscal Reporting
August 3, 2020
New EU Tax Package: VAT Priorities

On 15 July 2020, the European Commission (EC) adopted a new Tax Package, intended to increase tax compliance while reducing administrative burden on businesses. The Tax Package contains a number of proposals related to VAT, of which three in particular stand out: A single EU VAT registration for taxpayers; Modernized VAT reporting obligations; and Facilitated […]

August 3, 2020
Should Insurers Receive an IPT Holiday From Their Governments?

It’s been a tough year for businesses. Whilst many have accepted that 2020 is likely to be a year to forget, unfortunately tax still needs filing and paying. Tax authorities have been understanding – nobody could have foreseen this – and there has been a concerted effort to provide SMEs with tax relief and postponements […]

Asia Pacific E-Invoicing Compliance EMEA India
July 31, 2020
India: Last-Minute Changes to the Proposed E-Invoicing System

The October deadline is fast approaching for the Indian CTC invoicing mandate, but it remains a moving target. In a swift move that was published just two months prior to go-live, authorities have now changed the scope of who is affected by the reform, as well as updated the JSON format. Why the change? The […]