New Options for ACA Reporting
- Boutwell Fay
- 4 hours ago
- 2 min read
The IRS recently issued Notice 2025-15, providing guidance on how applicable large employers (“ALEs”) can meet the requirements for providing Forms 1095-C to full time employees as required by the Affordable Care Act (“ACA”). This update, which applies to reporting for calendar years after 2023, offers an alternative to automatically distributing Forms 1095-C to individuals. Employers who have not already implemented these changes may want to take advantage of the new options for ACA reporting for 2025.
Typically, ALEs (generally defined as employers with at least 50 full time employees, including full-time equivalent employees, in the prior calendar year) must file annual ACA information returns with the IRS by March 31 (February 28 if filing on paper) and furnish a copy of Form 1095-C to full time employees by January 31, with an automatic 30-day extension.
Under the Paperwork Burden Reduction Act passed at the end of 2024, ALEs are no longer required to send Form 1095-C to full time employees automatically, as long as they post a clear, conspicuous, notice on an accessible website (such as the employer’s website or intranet) informing full time employees that they can request a copy. Similar guidance applies for insurers and self-funded health plans to provide information regarding coverage in which individuals enrolled pursuant to Code Section 6055.
What ALEs need to know:
A website notice must be posted by the deadline for furnishing Forms 1095-C to employees, including the 30-day extension (March 2, 2026, for 2025 forms).
The notice must include an email address, a mailing address, and a phone number for employees to request a copy.
If requested, the Form 1095-C must be provided within 30 days or by January 31 of the following year, whichever is later.
New legislation also permits ALEs to provide Forms 1095-C electronically if an employee has affirmatively consented to electronic disclosure in accordance with existing Treasury Regulations.
These new options aims to reduce the administrative burden of automatically distributing forms while ensuring individuals still have access to their health coverage information.
If you have any questions about the new guidance, contact a Boutwell Fay attorney.
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