By: HUB’s EB Compliance Team
Massachusetts requires every employer with six or more employees in the state to file the Health Insurance Responsibility Disclosure ("HIRD") form each year. The reporting requirement applies to in-state and out-of-state employers with Massachusetts workers, regardless of whether the employer offers health insurance to its employees.
The following Q&A is designed to provide employers with answers relevant to completing the filing.
Questions and Answers
Q: What is the purpose of the HIRD form?
A: The HIRD form is designed to collect information about employer sponsored health insurance.
The HIRD form consists of questions related to each medical plan that you offer. Some information such as deductibles and out-of-pocket maximum levels may be found within your Summary of Benefits.
You may also be asked to provide:
- Eligibility waiting periods
- Minimum hours worked per week to qualify for health insurance
- Any eligibility categories i.e. full-time, part-time, salary, hourly
- Plan Year/Renewal Date
- Monthly cost for each plan including employer and employee cost share
The HIRD form does not seek information about non major medical benefits such as dental and vision coverage.
Q: Who has to file?
A: Any employer, in-state or out-of-state, that employed six or more employees in Massachusetts in any month during the past 12 months must file. The employer reports all full-time, part-time, and temporary workers in the quarterly wage report they submit to the Department of Unemployment Assistance (DUA)).
Q: Where do we file?
A: Groups must file the HIRD form directly through MassTaxConnect ("MTC"); the MTC will not accept paper forms or any other substitute.
You must log in to your MTC account, select the Withholding tax account, then choose the “File health insurance responsibility disclosure” hyperlink. Employers with multiple Federal Employer ID Numbers (“FEINs”) must file a separate HIRD form for each FEIN.
Q: When can we begin filing? When is the filing due?
A: The HIRD form reporting window opens on Sunday, November 15, 2026. The HIRD form filing deadline is Tuesday, December 15, 2026.
Q: We don’t offer health insurance. Do we still need to file?
A: Yes. Employers that do not offer coverage to their Massachusetts employees must still file the HIRD Form; they will simply answer “No” to the group health insurance coverage question and submit the form.
Q: We are no longer in business. Do we still file?
A: No. Employers that are no longer in business are not required to file. If a successor employer takes over a company’s operations and the company had or has six or more Massachusetts employees, the new entity must file.
Q: What if we made a mistake after submitting the HIRD Form?
A: The form can be amended. Log back in to MTC, go to the Withholding account, and select “File Amended Health Insurance Responsibility Disclosure.” The MTC only accepts one amended filing per day.
Q: Is there a penalty if you do not file?
An employer who knowingly falsifies or fails to file any information required on the HIRD form, shall be subject to a penalty of not less than $1,000 or more than $5,000 for each violation.
Q: Who do we contact with questions?
A: The Massachusetts Department of Revenue HIRD call center at (617) 466-3940, or the HIRD FAQ page.
Additional Resources
Conclusion
Employers with employees in Massachusetts need to determine whether they are required to complete the filing. Those who must complete the filing are required to do so by December 15, 2026 in order to avoid penalties.
If you have any questions, please contact your HUB advisor. View more compliance articles in our Compliance Directory.
NOTICE OF DISCLAIMER
Neither Hub International Limited nor any of its affiliated companies is a law or accounting firm, and therefore they cannot provide legal or tax advice. The information herein is provided for general information only and is not intended to constitute legal or tax advice as to an organization’s or individual's specific circumstances. It is based on Hub International's understanding of the law as it exists on the date of this publication. Subsequent developments may result in this information becoming outdated or incorrect and Hub International does not have an obligation to update this information. You should consult an attorney, accountant, or other legal or tax professional regarding the application of the general information provided here to your organization’s specific situation in light of your or your organization’s particular needs.
