ACA Form 1095-C compliance

Form 1095-C is filed and furnished to any employee of an Applicable Large Employers (ALE) member who is a full-time employee for one or more months of the calendar. ALE members must report that information for all twelve months of the calendar year for each employee. This is required under the Affordable Care Act.

ACA Form 1095-C Furnishing Requirements: What Employers Need to Know

As a reminder, beginning with forms issued in 2025 for the 2024 tax year, the IRS gave employers additional flexibility in how Form 1095-C is furnished to employees. That option remains in effect for the upcoming 2026 furnishing season. If you’re still mailing Form 1095-C to every employee, you’re not out of compliance — but you may be doing more than the IRS currently requires.

Key Recap Points for the 2025 Reporting Year

• The deadline to furnish Form 1095-C to employees for the 2025 tax year is March 2, 2026.
• Employers now have three compliant furnishing options:
  1. Print and mail Form 1095-C to employees, as done historically;
  2. Electronic delivery, provided the employee has affirmatively consented (similar to electronic W-2 consent requirements); or
  3. Furnish upon request only, provided specific notice and timing requirements are met.

• If forms are furnished electronically, employers must obtain prior, affirmative employee consent to receive the form in that manner.

Furnishing Forms Only Upon Request

Employers choosing the “upon request” option must comply with the following requirements:

1. Notice requirement: Employers must post a notice that is clear, conspicuous, and accessible, informing employees (and other covered individuals) that a copy of Form 1095-C will be provided upon request.

2. Method of notice: The notice may be posted on a benefits website or communicated through any reasonable method, so long as individuals are reasonably likely to see it.

3. Notice content: While no specific language is mandated, the notice must:

4. Timing of furnishing: The employer must provide the requested Form 1095-C by January 31, or within 30 days of the request, whichever is later.

5. Posting duration: The notice must remain available through at least October 15 of the year following the calendar year to which the form relates.

Additional guidance and background on this change is available from the Internal Revenue Service at:
https://www.irs.gov/instructions/i109495c

Source: Karol DeWitt, HR Advisor for WCI