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The Internal Revenue Service (IRS) has released the final 2024 forms and instructions for reporting under IRS Code Sections 6055 and 6056. The final instructions for the B series forms have been released, but only a draft version of the C series instructions for 2024 is available at this time.
- 2024 Forms 1094-B and 1095-B (and related instructions) can 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.
- 2024 Forms 1094-C and 1095-C (and related draft instructions) can be used by ALEs to report under Section 6056, as well as for combined Section 6055 and 6056 reporting by ALEs who sponsor self-insured plans.
No major changes were made to the final forms or instructions for 2024 reporting.
Electronic Filing Requirement
Starting January 1, 2024, if you file 10 or more returns, electronic filing is required. This includes various forms like W-2 and 1099, even if you file fewer than 10 of Forms 1094 and 1095. Use the ACA Information Returns (AIR) Program for electronic filing. While IRS guidance is technical, it offers valuable insights on filing standards and procedures.
Important Dates
- March 3, 2025: Individual statements for 2024 must be furnished within 30 days of January 31, 2025. An alternative method of furnishing Form 1095-B is available. Since the deadline falls on a weekend, the statements must be furnished by the next business day, which is March 3, 2025.
- March 31, 2025: Electronic IRS returns for 2024 must be filed by March 31, 2025.
Action Steps
Employers should become familiar with the forms and instructions for 2024 calendar year reporting and monitor future developments for the release of the final instructions for the C series forms. Download the bulletin for more details.
Additional IRS Resources
Information Reporting by Providers of Minimum Essential Coverage
Q&As: Information Reporting by Health Coverage Providers (Section 6055)
Information Reporting by Applicable Large Employers
Q&As: Employer Information Reporting on Form 1094-C and Form 1095-C
Q&As: Reporting of Offers of Health Insurance Coverage by Employers (Section 6056)
National Insurance Services is not a law firm and no opinion, suggestion, or recommendation of the firm or its employees shall constitute legal advice. Readers are advised to consult with their own attorney for a determination of their legal rights, responsibilities and liabilities, including the interpretation of any statute or regulation, or its application to the readers’ business activities.
