The IRS recently released updated guidance on Affordable Care Act (ACA) reporting requirements, introducing changes that employers need to be aware of to ensure compliance. The IRS issued Notice 2025-15, which provides guidance on the alternative manner of furnishing certain ACA health insurance coverage statements to individuals pursuant to IRC 6055 and 6056. The guidance does not affect the due date for filing ACA returns with the IRS. 

Reporting Requirement Changes

Starting with returns for calendar years following 2023, employers may now furnish Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, to individuals only upon request. To be considered as having furnished the form in a timely manner, employers must provide a notice indicating a copy is available upon request. 

This notice must be prominently posted and remain accessible through October 15 of the year following the calendar year to which the statement pertains. Applicable large employers (ALEs) are required to post the notice by the deadline for furnishing the statement, including the automatic 30-day extension. 

Upon receiving a request for Form 1095-C, the employer must furnish it by either January 31 of the year in which the form was initially required to be provided, or within 30 days of the request—whichever is later. Additionally, Form 1095-C may be delivered electronically. 

Historically, this method of furnishing Form 1095-C was only available to self-insured employers for non-full-time employees and non-employees enrolled in their plans. The expanded provision marks a significant shift, offering broader flexibility for employers moving forward. 

How We Can Help

We take the hassle out of ACA compliance with robust tools designed to streamline your payroll processes. From managing pre-tax payroll health care coverage deductions to tracking employee hours and calculating monthly full-time equivalent headcounts, our software ensures accuracy and efficiency. Additionally, our system notifies you the moment employees become eligible for ACA benefits, allowing you to act swiftly and remain compliant. By partnering with a payroll provider well-versed in ACA regulations, you can confidently navigate the complexities of compliance. Reach out to us today to discover how we can support your business with ACA compliance.