The greatly anticipated guidance relating to the alternative method of providing the 1095-C to employees is now available in IRS Notice 2025-15. As detailed in an earlier blog, President Biden signed the legislation providing for this methodology in late December of 2024. The newly released guidance states that employers no longer need to mail the 1095-C to every employee as long as they post a notice on their website indicating that these forms are now available upon request.
The guidance goes on to state that such notices must be posted by the form delivery due date, including the automatic extension period. This year’s notification would have required posting by March 3rd. The notice must remain posted on the employer site “through October 15th of the following the calendar year to which the form relates”. Employers will have met their timing requirements if they furnish the statement to an individual by the due date or within 30 days of an employee request, whichever is later.
Additionally, the guidance states that an employer may provide the requested form in electronic format according to the process laid out in Treas. Reg. § 301.6056-2. The full guidance is available at https://www.irs.gov/pub/irs-drop/n-25-15.pdf.
The deadline for furnishing Form 1095-C to employees for the 2024 tax year is March 3. Essentially, employers looking to comply with the furnishing requirements for future tax years have three options:
- Print and mail 1095-C forms as they have in the past;
- Electronically distribute forms with employee consent, as the guidance requires;
- Furnish 1095-C forms only upon request within the detailed parameters.
An important reminder for those applicable large employers, (ALEs), doing business in states with reporting requirements–you still must comply with standard furnishing requirements and deadlines in those jurisdictions. We will provide updates on state Affordable Care Act (ACA) positions as they evolve.
