ACA Reporting Update for 2026: New Options for Furnishing Forms 1095-B and 1095-C

As HR teams prepare for the upcoming ACA reporting cycle, a significant change in federal law offers new flexibility for how employers furnish Forms 1095-B/C to employees. This development, which applies to reporting for the 2025 coverage year, may help reduce administrative burden while still meeting IRS requirements.

The Paperwork Burden Reduction Act, enacted at the end of 2024, created an alternative method for providing Forms 1095-C. The alternative method was already in place for Forms 1095-B. Employers must still file both forms with the IRS as usual, but they no longer have to automatically mail or electronically deliver a form to every individual. Instead, organizations may choose to post an online notice informing employees and former employees that their form is available upon request.

This option is particularly appealing for employers who find that many employees disregard the mailed form because it is not needed to file a tax return.

How the New Furnishing Option Works

Under this rule, employers may use a Notice of Availability rather than direct distribution. To take advantage of this approach, an employer must:

1. Post a clear, easy-to-find notice on its website or employee portal stating that 1095 Forms are available upon request. The posting must remain online through October 15 of the year following the coverage year.
2. Provide straightforward instructions for requesting a form, including an email address or physical address for submissions and a phone number for questions.
3. Fulfill all requests within 30 days or by January 31, whichever is later.

The notice must be accessible, written in plain language and prominently displayed so individuals can easily recognize that it relates to health coverage tax reporting.

This posting method is optional. Employers may continue furnishing forms directly if that better fits their workforce.

Important Timing Considerations

For 2025 coverage reporting:

1. The Notice of Availability must be posted no later than March 2, 2026.
2. It must remain available until October 15, 2026.
3. IRS filing requirements are unchanged. Employers must still file Forms 1094 and 1095 with the IRS by the standard deadlines.

Watch for State-Level Requirements

Several states enforce separate ACA-style reporting mandates, and some require employers to issue forms directly to residents regardless of federal furnishing rules. Employers with employees in California, New Jersey, Rhode Island, Massachusetts or Washington, DC should confirm whether additional mailing or filing requirements apply.

Is the Posting Method Right for Your Organization?

As HR teams map out their 2026 compliance calendar, now is the time to evaluate whether this new flexibility is a practical fit. Consider:

• How easily your organization can maintain a compliant online notice.
• Whether you will be able to support tracking and fulfilling employee requests.
• Whether your employee population regularly uses online self-service tools.
• Any state-specific requirements that may still require mailing forms.

For many employers, the posting option could reduce printing and postage costs, streamline ACA tasks and eliminate the time spent responding to returned mail.

What HR Should Do Now

• Decide whether your organization will adopt the Notice of Availability in 2026.
• Draft and test your online notice well ahead of the reporting deadline.
• Implement process to manage and fulfill requests.
• Review state requirements to ensure a consistent compliance approach.

With thoughtful preparation, this new rule can help HR teams simplify ACA reporting while maintaining compliance at both the federal and state levels.

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This article is for informational purposes only and is not intended as legal, tax, or benefits advice. Readers should not rely on this information for taking (or not taking) any action relating to employment, compliance, or benefits. Always consult with a qualified professional before making decisions based on this content.