As HR professionals begin preparing for ACA reporting season, there’s an important new development that may simplify the process for 2025 coverage reporting. On December 23, 2024, the Paperwork Burden Reduction Act (Public Law 118-167) changed how employers can furnish Forms 1095-C to employees.
For over a decade, Applicable Large Employers (ALEs), those with 50 or more full-time equivalent employees, have been required to file Forms 1095-C with the IRS and furnish copies to employees. While employers must still file forms with the IRS, the new law offers an alternative furnishing method that may significantly reduce administrative workload.
Under this new option, employers are no longer required to automatically mail or electronically deliver Forms 1095-C to every employee. Instead, they may post a notice online informing individuals that their form is available upon request. When an employee or former employee requests their form, the employer must provide it within 30 days or by January 31—whichever is later.
To comply with this new posting option, employers choosing to adopt it must:
- Post a clear, accessible notice on their website or employee portal stating that Forms 1095-C are available upon request. The notice must remain available through October 15 of the year following the coverage year.
- Provide simple instructions for requesting the form, along with contact details—an email address, physical address, and phone number—for employee inquiries.
- Respond promptly to all requests within the required timeframe.
The notice must be written in plain language, large enough to be easily noticed, and clearly state that it pertains to health insurance coverage reporting for tax purposes.
While this change can ease reporting administration, employers should note two important caveats. First, state-level requirements may differ as some states still require that physical copies of Form 1095-C be mailed to residents regardless of federal changes. Second, IRS filing obligations remain unchanged; employers must still submit Forms 1095-C (and 1095-B, if applicable) to the IRS as usual.
This new rule is designed to reduce unnecessary paperwork, especially for employers whose employees often disregard mailed 1095-C forms because the information is not required to file a tax return. Instead, employees can now request a copy only if they need it.
For HR teams, early fall is the perfect time to consider whether this approach makes sense for next year’s reporting season. Evaluate how easily your organization could post and maintain an online notice, track and fulfill requests, and coordinate with your ACA reporting vendor or payroll provider. For organizations comfortable with electronic communication and employee self-service, the posting method could save time, reduce mailing costs, and simplify year-end processes.
Employers planning to adopt this option should draft and test their online notice well before the January 31 furnishing deadline and confirm that employees know where to find it. By taking steps now, HR teams can take advantage of this new flexibility and ensure a smoother, more efficient ACA reporting process in 2026.
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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.
