No. Both 4980H(a) and 4980H(b) penalties are triggered only when at least one full-time employee claims a premium tax credit (subsidy) on the ACA marketplace. As long as all employees either accept your CHOICE offer, obtain coverage elsewhere without subsidies, or remain uninsured, no penalties apply.
This is why ensuring your CHOICE plan is affordable (generally below 10.22% of employee household income for 2027) helps protect against penalties.