IRS issues guidance on alternative manner for 1095 forms

The IRS issued guidance (Notice 2025-15) on the alternative manner for providing Forms 1095-B and 1095-C, recently added by the Paperwork Burden Reduction Act, passed into law at the end of last year.

IRS Form 1095-B is used to report certain information to the IRS and to employees about individuals who are covered by minimum essential coverage under a health plan. IRS Form 1095-C is used by Applicable Large Employers (ALE) — generally those with 50 or more full-time employees, including full-time equivalent employees, in the prior calendar year — to report about offers of health coverage and enrollment in health coverage for their employees. These forms were first required to be furnished by the Affordable Care Act of 2010 (ACA).

These forms generally must be furnished on or before Jan. 31 of the year following each calendar year. However, the IRS has provided an automatic 30-day extension — for example, for 2024, the forms must be provided by March 3, 2025 (including an additional day since March 2 falls on a Sunday).

The Paperwork Burden Reduction Act provides an alternative manner for providing these forms, which provides that the requirement to furnish the forms generally will be treated as satisfied if the employer provides a clear and conspicuous notice, in a location on its website that is reasonably accessible to all covered employees, stating that an employee may receive a copy of the forms upon request. In addition, this notice must be timely posted and retained on the website through Oct. 15^` of the year following each calendar year.

Notice 2025-15 provides guidance regarding this alternative manner including, but not limited to, that the required notice must be posted on the employer’s website by the due date for furnishing the forms, including the automatic 30-day extension — for example, by March 3, 2025, for 2024 forms. In addition, the notice clarifies that a requested form would be considered timely furnished to an individual if it is provided not later than the later of Jan. 31 of the year following the calendar year or 30 days after the date of the request.

The guidance provided by Notice 2025-15 is effective beginning with the forms required for the 2024 calendar year.

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