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Avoiding ACA pay-or-play penalties: What employers need to know

Authors: Scott McLellan, Jonathon Trionfi

April 27, 2026 / 5 min read

Discover key strategies for avoiding ACA pay-or-play penalties, including tracking full-time status, applying the updated affordability percentage for 2026, using affordability safe harbors, and timely ACA reporting.

Are you confident your organization is positioned to avoid ACA pay-or-play penalties? This bulletin outlines key strategies that applicable large employers (ALEs) can use to help meet the Affordable Care Act’s (ACA) employer mandate requirements and reduce potential penalty exposure. Topics include tracking full-time status, applying the updated affordability percentage for 2026, using affordability safe harbors, timely ACA reporting, and more — with practical considerations to support ongoing compliance.

If you have questions about ACA pay-or-play requirements or your organization’s compliance strategy, please contact your Plante Moran Group Benefit Advisor.

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This Compliance Update is not intended to be exhaustive, nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice.