ACA Reporting Requirements Revised for 2025

by MeLissa Crockett

Thanks to the recently enacted Employer Reporting Improvement Act and Paperwork Burden Reduction Act, two key changes will simplify the reporting process for employers.

  • Form 1095-C Distributed Only on Request: Employers are no longer required to distribute Form 1095-C to all full-time employees. Instead, these forms may be provided upon request from individuals. Employers must notify employees of their right to request these forms. Such requests must be fulfilled by January 31 or 30 days after the date of the request, whichever is later. The IRS allows for these forms to be provided electronically to the individuals.
  • TIN Change: The IRS now permits employers to report an individual’s full name and date of birth on Form 1095-C if the individual’s taxpayer identification number (TIN) cannot be obtained. Previously, employers were required to report minimum essential coverage using the individuals TIN.

For calendar year 2024, an Applicable Large Employer (ALE) must still prepare and file Form 1095-C with the IRS by the deadlines. The due date is the next business day if it falls on a weekend or legal holiday. It should be noted that all employers that file a combined total of 10 or more information returns must file the forms electronically.

  • February 28, 2025 for paper filing Forms 1094-C and 1095-C
  • March 31, 2025 for electronic filing Forms 1094-C and 1095-C

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