On Nov. 5, 2025, the Internal Revenue Service (IRS) issued final instructions for Affordable Care Act (ACA) reporting under Internal Revenue Code Sections 6055 and 6056. The release follows the IRS’ earlier publication of the final reporting forms and draft instructions for the 2025 calendar year.
-The 2025 Forms 1094-B and 1095-B (and related instructions) 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 Forms 1094-C and 1095-C (and related instructions) 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 final forms or instructions for 2025 reporting.
Final Instructions Highlight Alternative Furnishing Method
Both sets of instructions clarify that reporting entities are no longer required to automatically furnish Forms 1095-B and 1095-C to individuals (as required under the original reporting rules). Instead, reporting entities may post a notice on their websites informing individuals that they can request a copy of the statement. The requirement to provide the statement is met if the notice is:
-Clear, conspicuous and reasonably accessible to all covered individuals;
-Timely posted, which for calendar year 2025 is by March 2, 2026;
-Retained on the website until Oct. 15, 2026; and
-Furnished to any requesting individual by the later of Jan. 31, 2026, or 30 days after the date of the request.
The instructions also outline the required content for the website notice, which remains unchanged from the prior reportingyear.
Action Steps
Employers should become familiar with the forms and instructions for 2025 calendar year reporting and begin to exploreoptions for filing ACA reporting returns electronically (e.g., they may be able to work with a third-party vendor to complete theelectronic filing). Reporting entities that may be in a position to perform their own electronic reporting can review the IRS’ ACAInformation Returns (AIR) Program webpage.