- On November 11, 2025
- ACA
On November 5, 2025, the Internal Revenue Service (IRS) released the final instructions for Affordable Care Act (ACA) reporting requirements under Internal Revenue Code Sections 6055 and 6056. This update follows the agency’s earlier release of the finalized reporting forms and draft guidance for the 2025 calendar year.
Reporting Forms Overview
- Forms 1094-B and 1095-B (with instructions) will be used in 2025 by organizations that provide minimum essential coverage (MEC)—including self-insured employers that are not classified as applicable large employers (ALEs)—to meet the reporting requirements under Section 6055.
- Forms 1094-C and 1095-C (with instructions) are for ALEs, who must report under Section 6056. These forms also serve a dual reporting purpose for ALEs that sponsor self-insured health plans, covering both Sections 6055 and 6056 obligations.
The IRS noted that the 2025 forms and instructions contain no significant revisions from prior years.
Alternative Method for Furnishing Statements
The finalized instructions reiterate that reporting entities do not have to distribute Forms 1095-B and 1095-C to covered individuals automatically. Instead, they can satisfy the furnishing requirement by posting a notice on their website that informs individuals how to request a copy of their form.
To meet IRS requirements, the website notice must be:
- Clearly written, easy to find, and accessible to all covered persons
- Posted by March 2, 2026 (for 2025 calendar year reporting)
- Maintained on the website through October 15, 2026
- Responded to promptly—statements must be provided no later than January 31, 2026, or within 30 days of receiving a request, whichever is later.
The content required in the website notice remains unchanged from the previous year’s guidance.
Next Steps for Employers
Employers should review the finalized 2025 ACA reporting forms and instructions and begin preparing for electronic filing. Many organizations partner with third-party vendors to manage this process. Those who plan to file electronically on their own should review the IRS’s ACA Information Returns (AIR) Program webpage for details on setup and submission.
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