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Still Waiting for the IRS to Issue Final Versions of Forms 1094/1095-B/C

  • On October 1, 2025
  • ACA

In June 2025, the Internal Revenue Service (IRS) released draft 2025 forms for Affordable Care Act (ACA) reporting under Internal Revenue Code Sections 6055 and 6056. Thereafter, on September 17, 2025, draft instructions for the C series forms were released; however, the IRS has not yet released draft instructions for the B series forms.

  • The 2025 draft Forms 1094-B and 1095-B are draft versions of forms that will be used by providers of minimum essential coverage—including self-insured plan sponsors that are not applicable large employers (ALEs)—to report under Section 6055.
  • The 2025 draft Forms 1094-C and 1095-C (and related draft instructions) are draft versions of forms that will be used by ALEs to report under Section 6056 as well as for combined Section 6055 and 6056 reporting by ALEs that sponsor self-insured plans.

No major changes were made to the draft forms or the draft C series instructions for 2025 reporting. However, certain changes may be made once the forms are finalized.

Key Dates

ACA reporting for the 2025 calendar year is due in early 2026. Electronic IRS returns for 2025 must be filed by March 31, 2026. Reporting entities that file at least 10 returns during the calendar year are required to file electronically.

Forms 1095-B and Forms 1095-C may be furnished to individuals upon request. To do so, reporting entities must post a clear and conspicuous notice on their websites informing individuals of the availability of these forms. Alternatively, reporting entities can provide Forms 1095-B and 1095-C to individuals by March 2, 2026. Reporting entities should continue to comply with applicable state reporting requirements, which may differ from federal obligations.

Action Steps

Employers should become familiar with the draft forms and available instructions for the 2025 calendar year reporting, keeping in mind that these are draft versions only and should not be relied upon for filing purposes. The draft C series instructions emphasize that the formatting directions they contain are for preparing paper returns. When filing forms electronically, the formatting set forth in the IRS’s XML Schemas and business rules must be followed. Employers should continue to monitor for the release of the 2025 draft B series instructions and stay informed of any additional IRS updates to ensure full compliance with their reporting obligations.

Additional IRS Resources

The IRS provides the following resources for reporting entities:

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