1095-C Compliance: New Rules & Employer Options

February 15, 2025

What Changed for Form 1095-C Distribution?

Previously, employers were required to deliver Forms 1095-C (and 1095-B) directly to all recipients each year. Under the new law, employers can now satisfy the ACA’s furnishing requirement by providing a “clear, conspicuous, and accessible notice” informing recipients that they may request a copy of their Form 1095. Upon receiving such a request, the employer must promptly provide the form.

This alternative furnishing method is available only if specific criteria are met, and it does not eliminate the requirement to file Forms 1094/1095 with the IRS.

IRS Guidance for Employers

While guidance for Form 1095-B was already available, the IRS has now confirmed that the same notice requirements apply to Form 1095-C. Employers can rely on the previously issued instructions for both forms.

Official IRS guidance:

Notice Requirements for Forms 1095-C and 1095-B

To use the alternative distribution option, employers must:

Post a clear and conspicuous notice on a website that is reasonably accessible to all possible Form 1095 recipients. The employer’s public-facing website is generally the most appropriate location.
The notice can be linked from a “Tax Information” statement on the website’s main page, directing users to a secondary page with the header “IMPORTANT HEALTH COVERAGE TAX DOCUMENTS” and the actual notice.
The notice must include an email address, physical address, and telephone number that recipients can use to request a copy of their Form 1095.
For the 2024 reporting year, the notice must be posted by March 3, 2025, and remain available through October 15, 2025.
If an employer receives a request for a Form 1095 after posting the notice, the form must be provided within 30 days. Unless the individual consents to electronic delivery, the form must be hand-delivered or mailed.

Reference:

Ongoing Filing and State Requirements

It’s important to note that this relief does not change the requirement for employers to create and file Forms 1094/1095 with the IRS. All Applicable Large Employers (ALEs) and non-ALEs with self-insured or level-funded health plans must still file their 2024 forms with the IRS by March 31, 2025.

IRS: ACA Information Center for Applicable Large Employers (ALEs)

Additionally, state-level ACA form furnishing requirements remain unaffected by this federal alternative. Employers should continue to monitor and comply with any state-specific mandates.

Should Employers Use the Alternative Option?

Employers who wish to continue furnishing Forms 1095-C to all recipients by mail or other traditional means may do so. The new law and IRS guidance simply provide an alternative for those seeking to reduce paperwork and administrative costs. Given the March 3, 2025, posting deadline for the 2024 reporting year, many employers may first utilize this option for 2025 filings due in 2026.

Key Takeaways

The Paperwork Burden Reduction Act allows an alternative method for furnishing Forms 1095-C and 1095-B, provided strict notice requirements are met.
Employers must still file all required forms with the IRS and comply with state-level requirements.
The IRS has confirmed that the same notice requirements apply to both Forms 1095-B and 1095-C.
Employers should review the official IRS instructions and ensure compliance with all deadlines and notice requirements.

At Benefit Group, we’re here to simplify the process. Whether you choose the new alternative or traditional delivery for Form 1095-C, our experts provide tailored guidance and support. Contact us today to ensure accurate, timely, and hassle-free ACA reporting. We’re committed to optimizing your benefits strategy while minimizing administrative burdens.