ACA Reporting for 2025: What Brokers Need to Know for Early 2026 Filings

Quick Answer

The IRS finalized 2025 ACA reporting instructions on October 30, 2025. The big update is that employers no longer have to proactively send Forms 1095-B or 1095-C if they post a compliant website notice and provide forms upon request (except for New Jersey residents, who must still receive forms automatically). Deadlines and reporting codes remain unchanged, but the new six-year statute of limitations makes accuracy and XML verification more important than ever.

Why This Matters to Brokers Right Now

ACA reporting often lands in the middle of renewals, payroll changes, and year-end cleanup. It is easy for employers to assume nothing has changed and move on. But even small procedural updates, like how 1095s are delivered or whether reporting is truly complete, can create downstream penalty exposure.

As a broker, this is one of those moments where proactive guidance protects your clients and reinforces your value. Employers will look to you to explain what changed, what did not, and what they need to do now to avoid issues in 2026 and beyond.

What Changed in the Final 2025 ACA Reporting Instructions

On October 30, 2025, the IRS released final instructions for:

• Forms 1094-B and 1095-B

• Forms 1094-C and 1095-C

  
  

The only substantive change highlighted in the “What’s New” section is official confirmation of an alternative method for furnishing 1095 statements to individuals upon request if proper website disclaimers are provided.

The New Furnishing Relief, Explained Simply

Employers are no longer required to automatically send Forms 1095-B or 1095-C to individuals if all of the following are true:

• The employer posts a clear and conspicuous notice on a public-facing website from March 2 through October 15.

• The notice explains the process to request the 1095.

• The employer provides the form within 30 days of a request.

  
  

This relief applies for 2025 forms delivered in early 2026.

Important exception:

• New Jersey residents must still receive the 1095 proactively, regardless of website notice.

Who This Applies To

You should be flagging this for clients in these categories:

Applicable Large Employers (ALEs)

• ALEs for calendar year 2025 (based on averaging 50 or more full-time and equivalents in 2024 on their own or by being part of a controlled group or affiliated service group of employers who must combine their 2024 counts)

• Required to file Forms 1094-C and 1095-C in early 2026

  
  

Non-ALE Employers with Self-Insured Exposure

• Employers who were not ALEs in 2025 but sponsored:

  • A level-funded or self-insured medical plan, or

  • An ICHRA (individual coverage health reimbursement arrangement)

• Required to file Forms 1094-B and 1095-B for applicable months

  
  

The only employers fully exempt from ACA reporting in early 2026 are non-ALEs that:

• Sponsored a fully insured medical plan for all 12 months of 2025, or

• Did not offer medical benefits at all in 2025.

  
  

All other employers still have reporting obligations.

What the Website Disclaimer Must Include

If an employer wants to rely on the new relief to only issue 1095 forms on request (except for NJ residents), the website notice must be easy to find and easy to understand. The IRS expects language that the average person can reasonably see and comprehend.

A common structure includes:

• A prominent link on the main webpage, such as a “Tax Information” link

• That link going to a secondary page containing:

  • “IMPORTANT HEALTH COVERAGE TAX DOCUMENTS” in all caps

  • Instructions on how to request Form 1095-B or 1095-C

  • An email address, mailing address, and phone number for requests

    
    

Timing matters. The notice must be posted:

• No later than March 2, 2026

• Maintained through at least October 15, 2026

What Did Not Change

This is where brokers can offer reassurance.

For 2025 reporting:

• Reporting codes remain the same.

• Forms did not structurally change.

• Deadlines remain unchanged.

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Key deadlines to reinforce with clients:

• Forms 1095 to individuals by Monday, March 2, 2026 (subject to state-specific rules)

• Electronic filing of 1094 and 1095 forms with the IRS by Tuesday, March 31, 2026

Why Accuracy Matters More Than Ever

Congress also introduced a six-year statute of limitations for IRS enforcement of applicable large employer shared responsibility penalties under Section 4980H.

Here is the catch that many employers will miss:

• The six-year clock does not start until accurate and complete ACA reporting is filed.

• The start date is the later of:

  • March 31, 2026, or

  • The date the IRS receives all correct forms and data

    
    

If reporting is incomplete, inaccurate, or contains XML errors, the statute of limitations does not begin. That creates extended exposure for penalty assessments.

This is why brokers should be encouraging employers to:

• Review draft 1095 forms carefully.

• Audit the XML file that is actually transmitted to the IRS.

• Confirm corrections are made before final submission.

Broker Action Steps

Use this checklist with your clients now:

• Confirm whether the employer is an ALE for 2025 (based on 2024 counts).

• Identify whether any self-insured or ICHRA months trigger B-series reporting.

• Decide whether the employer will proactively distribute 1095s or rely on the website notice.

• Ensure the public website disclaimer is drafted and scheduled for posting by March 2, 2026.

• Flag New Jersey residents for proactive distribution regardless of notice.

• Verify ACA reporting vendor contracts are signed and electronic filing is confirmed.

• Encourage a review of both the forms and the XML file before submission.

Frequently Asked Questions

Can employers really stop mailing 1095 forms?

Yes, if they post a compliant website notice and provide the form within 30 days of a request. New Jersey residents are the exception and must still receive forms automatically.

Does this relief apply to both 1095-B and 1095-C?

Yes. The alternative furnishing method applies to both B and C forms.

Are there any other changes in the final instructions?

No. Other than routine updates to dates, affordability percentages, and penalty amounts, the instructions are unchanged.

When does the six-year statute of limitations begin?

It begins after the later of the filing deadline or the date the IRS receives accurate and complete reporting. Errors or missing data delay the start.

Do employers still need to file with the IRS electronically?

Yes. Virtually all employers required to file ACA reporting must do so electronically, meaning reporting is submitted via an XML file.

Final Thoughts

ACA reporting may feel routine, but small changes in process can carry long-term consequences. The new furnishing relief gives employers flexibility, but only if it is implemented correctly. At the same time, the extended statute of limitations raises the stakes for accuracy.

This is exactly where brokers make a difference. By raising these issues early, you help employers avoid missteps, strengthen compliance, and demonstrate proactive leadership. At BCS, our role is to help you translate these rules into clear, actionable steps so compliance supports your client relationships with clarity, not confusion.