ACA Reporting for 2025: Deadlines and Changes Before Forms 1094-C and 1095-C Are Due

ACA reporting season starts in a few weeks. For calendar year 2025, applicable large employers (ALEs) and employers with self-insured plans face the familiar filing obligations, but with more flexibility than in past years, thanks to two laws signed on December 23, 2024, and IRS guidance issued this year.

Here's what brokers should confirm with clients now, before the January rush.

Who files

• Applicable large employers (generally 50 or more full-time employees, including full-time equivalents, in the prior year) file Form 1094-C and a Form 1095-C for each full-time employee, reporting offers of coverage month by month. ICHRA offers are reported here too.
• Self-insured plan sponsors, including those with level-funded plans, report coverage for covered individuals. ALEs do that in Part III of Form 1095-C; smaller self-insured employers generally use Forms 1094-B and 1095-B.

Key dates for 2025 reporting

• Furnish Form 1095-C to full-time employees: March 2, 2026
• File with the IRS on paper: March 2, 2026
• File with the IRS electronically: March 31, 2026

Employers that must file 10 or more information returns in the aggregate (including Forms W-2 and 1099) must file electronically, so most ALEs will be e-filing.

Change 1: Furnishing on request (Paperwork Burden Reduction Act)

The Paperwork Burden Reduction Act (Public Law 118-167) added an alternative manner of furnishing Forms 1095-B and 1095-C. In Notice 2025-15, the IRS explained how it works, including for ALEs furnishing Form 1095-C to full-time employees:

• Post a notice on the employer's website that is clear, conspicuous, and accessible, stating that individuals may request a copy of their statement. For 2025 statements, post it by March 2, 2026 (the furnishing due date, including the automatic 30-day extension).
• Keep it posted through October 15, 2026.
• Furnish on request no later than the later of January 31, 2026, or 30 days after the request is received.

Employers still have to file every return with the IRS. The change only affects whether forms must be automatically sent to individuals.

What to discuss with clients:

• Do they want to stop mailing forms? Some employers will keep mailing because employees expect it or because state rules require similar statements.
• Several states have their own individual mandate reporting requirements, so check whether state rules allow the same approach before relying on the federal relief.
• Who will receive and respond to requests within 30 days? Put a process in place, especially for vendors handling reporting.

Change 2: The Employer Reporting Improvement Act

The Employer Reporting Improvement Act (Public Law 118-168) made several practical changes:

• More time to respond to penalty letters. The IRS must allow at least 90 days from the first letter proposing an employer shared responsibility payment (Letter 226-J) for the employer to respond. Previously, the typical response window was 30 days.
• A statute of limitations. Employer shared responsibility payments must now be assessed within six years of the Form 1094-C filing due date (or the date filed, if later), for returns due after December 31, 2024.
• Date of birth instead of TIN. When a reporting entity can't collect a covered individual's taxpayer identification number, a full name and date of birth may be used instead.
• Electronic delivery consent. An individual who has previously consented to receive Form 1095-C electronically from the employer is treated as having consented going forward, unless the consent is revoked.

ICHRA reporting reminders

ICHRA sponsors that are ALEs need to get a few specific fields right on Form 1095-C:

• Line 14: ICHRA offers use codes 1L through 1U. Most of these codes indicate who was offered the ICHRA (employee only, employee and dependents, employee and spouse, or family) and whether affordability was based on the employee's residence or primary work location; others cover an unaffordable ICHRA or an ICHRA offered to someone who wasn't a full-time employee.
• Line 15: The employee's required contribution for the lowest-cost silver plan, after subtracting the monthly ICHRA amount.
• Line 17: The ZIP code used for the affordability calculation, either the employee's residence or primary work location under the location safe harbor.

These entries come directly from the affordability analysis, which is another reason to keep good records of the premiums, ZIP codes, and safe harbors used.

Penalties for reporting failures

For 2025 returns, the IRS instructions list a penalty of $340 per return for failure to file a correct information return, and $340 per statement for failure to furnish a correct statement, subject to annual maximums. Penalties can be reduced for timely correction, and there's relief for reasonable cause.

A pre-season checklist

1. Confirm ALE status based on 2024 employee counts.
2. Gather monthly offer and enrollment data for all of 2025, including ICHRA offers, waivers, and terminations.
3. Check codes for mid-year changes, new hires in waiting periods, and COBRA.
4. Decide on the alternative furnishing method and draft the website notice.
5. Confirm e-filing setup through the IRS AIR system or a vendor.
6. Collect missing TINs, or prepare to use dates of birth where permitted.
7. Calendar the deadlines: March 2 to furnish or post, March 2 for paper filing, March 31 for e-filing.

The bottom line

The new laws reduce some of the paperwork burden and give employers more time to respond if the IRS proposes a penalty. They don't remove the core obligation to report offers of coverage accurately. Start the data review in December so January isn't spent chasing missing information.