2025 ACA Reporting Forms & Instructions Finalized

The IRS released final instructions for ACA reporting under Sections 6055 and 6056, following the earlier publication of the final forms and draft instructions for the 2025 calendar year.

• 2025 Forms 1094-Band 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.

• 2025 Forms 1094-C and 1095-C (and related 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 2025 reporting.

Final Instructions Highlight Alternative Furnishing Model

Reporting entities are no longer required to automatically furnish Forms 1095-B and 1095-C to individuals. Instead, they may post a notice on their website informing individuals that statements are available upon request. The notice requirement is met if the notice is:

• Easily accessible and clearly visible to all covered individuals;
• Timely posted, the deadline for calendar year 2025 is March 2, 2026;
• Retained on the website until October 15, 2026; and
• Statements must be provided within 30 days of a request or by January 31, 2026, whichever is later.

The website notice content requirements remain the same as last year.

Action Steps

Employers should review the 2025 ACA reporting forms and instructions and begin evaluating electronic filing options, such as partnering with a third-party vendor or utilizing the IRS’ ACA Information Returns (AIR) Program webpage for direct submission. 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)