January 2026
Stephanie Hall, Associate Director Benefits Compliance
The IRS has released the final 2025 forms and instructions for reporting under IRC Sections 6055 and 6056 (Forms 1094-B, 1095-B, 1094-C, and 1095-C). No major changes were made to the final forms or instructions for the 2025 reporting. However, the instructions added information with respect to the alternative method for furnishing statements. More specifically, the instructions clarify that employers are no longer required to automatically furnish Form 1095-C to individuals (as required under the original reporting rules). Instead, an employer may post a notice on its website informing individuals that they can request a copy of the form.
The requirement to provide the form is met if the notice is:
- Clear, conspicuous, and reasonably accessible to all responsible individuals;
- Timely posted, which for tax year 2025 is by March 2, 2026;
- Retained on the website until October 15, 2026; and
- Furnished to any requesting individual by the later of January 31, 2026, or 30 days after the date of the request.
The instructions also outline the required content for the website notice (see the specific section about “alternative manner of furnishing statements” in the instructions).
All other ACA reporting for employers under IRC Sections 6055 and 6056 for the 2025 calendar year is due as follows:
- Fully insured applicable large employer (“ALE”) and self-insured ALE: furnish Form 1095-C to individuals by March 2, 2026 (on paper, by mail, or electronically if specific, prior consent was given).
- Self-insured non-ALE: furnish Form 1095-B to responsible individuals by March 2, 2026 (on paper, by mail, or electronically if specific, prior consent was given).
- Fully insured ALE and self-insured ALE: File Forms 1094-C and 1095-C electronically with the IRS by March 31, 2026.
- Self-insured non-ALE: File Forms 1094-B and 1095-B electronically with the IRS by March 31, 2026.
State reporting considerations:
Several states, including California, Massachusetts, New Jersey, and Rhode Island, as well as the District of Columbia, have their own reporting requirements to evidence an employee’s compliance with the individual mandate. Deadlines may differ from the federal law requirements noted above. In addition, the alternative method of furnishing the statements allowed for federal reporting may not be available for reporting in these states. Employers should continue to comply with applicable state reporting requirements.
Employer action items:
- Employers should become familiar with these forms and instructions for the 2025 calendar year reporting and, if they have not already done so, work with their ACA reporting vendor to prepare and file the forms by the applicable deadlines.
- Small employers with level or self-funded health plans will need to check to see if the insurer or third-party administrator will furnish and file the forms on their behalf. If not, they will need to work with a vendor to complete the forms for furnishing to those individuals covered under the plan and for electronic filing with the IRS.
Additional Information and Resources
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