The IRS has officially released the final Affordable Care Act (ACA) reporting forms and instructions for the 2025 calendar year, providing employers and coverage providers with clarity as they prepare for upcoming compliance obligations .

On November 5, 2025, the IRS issued final guidance under Internal Revenue Code Sections 6055 and 6056, following the earlier release of draft forms and instructions. While there are no major structural changes to the forms themselves, there are important reminders and clarifications that employers should not overlook.

Which Forms Apply to Your Organization?

The finalized instructions confirm the continued use of the following forms:

Forms 1094-B and 1095-B

Used by providers of minimum essential coverage, including self-insured employers that are not Applicable Large Employers (ALEs), to satisfy Section 6055 reporting requirements.

Forms 1094-C and 1095-C

Used by Applicable Large Employers (ALEs) to comply with Section 6056 reporting. ALEs that sponsor self-insured plans will continue to use these forms for combined reporting under both Sections 6055 and 6056.

The IRS confirmed that no major changes were made to the final forms or instructions for 2025 reporting .

Continued Use of the Alternative Furnishing Method

One of the most significant clarifications—carried forward from prior years—is the IRS’s continued allowance of the alternative furnishing method for Forms 1095-B and 1095-C.

Employers and other reporting entities are no longer required to automatically mail Forms 1095-B or 1095-C to individuals. Instead, they may satisfy the furnishing requirement by posting a clear website notice informing individuals that they may request a copy of their statement.

To remain compliant, the notice must be:

  • Clear, conspicuous, and reasonably accessible to all covered individuals
  • Posted by March 2, 2026 for the 2025 reporting year
  • Maintained on the website through October 15, 2026
  • Accompanied by timely fulfillment of requests—no later than January 31, 2026, or within 30 days of a request, whichever is later

The required content of the notice itself remains unchanged from prior years.

Action Steps Employers Should Take Now

Even without major form changes, ACA reporting remains complex and detail-driven. Employers should:

  • Review the finalized 2025 forms and instructions carefully
  • Confirm whether they qualify as an ALE and which forms apply
  • Evaluate electronic filing options, including third-party ACA reporting vendors
  • Ensure internal systems and payroll/benefits data are aligned for accurate reporting

The IRS continues to support electronic filing through its ACA Information Returns (AIR) Program, which may be an option for organizations with the resources to file directly.

Need Help Navigating ACA Reporting?

Let us help you stay compliant—so you can stay focused on running your business.

ACA reporting errors can result in costly penalties and unnecessary administrative burden. If you have questions about your 2025 reporting obligations, furnishing requirements, or filing strategy, we’re here to help.

We invite you to reach out to our Director of Compliance for personalized guidance, compliance support, and hands-on assistance to ensure your ACA reporting is accurate, timely, and stress-free.