ACA reporting: Forms 1094-C and 1095-C

The IRS enforces the employer mandate with information returns. An ALEBenefitsApplicable large employerAn employer that averaged at least 50 full-time employees, full-time equivalents included, over the prior calendar year — the employers the ACA's employer mandate and Form 1095-C reporting apply to. Companies under common control are counted together files a Form 1095-CBenefitsForm 1095-CThe statement an ALE files for each full-time employee, month by month, of the coverage it offered and what the cheapest option cost — sent to the IRS with Form 1094-C, and the evidence the IRS uses for §4980H. For 2025, filed by March 2, 2026 on paper or March 31 electronically for every employee who was full-time in any month, showing month by month what coverage was offered and what the cheapest option cost, with a Form 1094-C transmittal. Whoever provides the coverage reports who was covered: the carrier, for an insured plan, on Form 1095-BBenefitsForm 1095-BThe statement of minimum essential coverage provided, filed with Form 1094-B by insurers — and by small employers that are not ALEs but sponsor a self-insured plan.

The Paperwork Burden Reduction Act, signed December 23, 2024, ended automatic mailing. An employer meets the furnishing requirement by posting a clear, conspicuous and accessible notice on its website that an individual may request a copy, and sending one within 30 days of a request — no later than the later of January 31 or 30 days after the request. The notice must go up by the furnishing due date and stay up through October 15. The returns to the IRS are still filed.

Stop producing Forms 1095-C because the law no longer requires mailing them

Post the website notice, answer requests within 30 days, and still file 1094-C and 1095-C with the IRS