Internal Revenue Service Issues Guidance on New ACA Reporting Opt

Somewhere in America, a payroll manager just opened their inbox and saw the words “ACA reporting” and “new guidance” in the same sentence. Their coffee got colder on the spot.

If that sounds familiar, here’s the good news: the IRS has clarified how a newer, paperwork-slimming option works for Affordable Care Act (ACA) statementsspecifically the annual forms employees and covered individuals used to receive automatically (hello, Forms 1095-B and 1095-C). The short version: in many cases, you can stop mailing stacks of forms to everyone and instead post a clear website notice that lets people request a copy when they actually need it.

The long version (the one you need to stay compliant, reduce confusion, and avoid a “Why didn’t I get my form?” stampede) is what we’ll cover hereusing plain English, real-world examples, and just enough humor to keep you awake.

What Changed (and Why the IRS Issued Guidance)

ACA reporting has always had two big responsibilities for employers and coverage providers:

• File information returns with the IRS (think: Forms 1094/1095).
• Furnish statements to individuals (employees, covered individuals, or “responsible individuals,” depending on the form).

Historically, that furnishing requirement meant printing (or emailing with consent) a form to basically everyone who might possibly care. In practice, a lot of people didn’t need the form for their federal returnespecially after the federal “individual mandate penalty” effectively became $0 for most taxpayers. Still, the forms kept coming… like holiday fruitcake, but less delicious and more likely to involve a compliance penalty if mishandled.

Congress passed two late-2024 laws that aimed to modernize and streamline ACA reporting burdens. One of them created a statutory “request-based” furnishing option for both Forms 1095-B and 1095-C, as long as entities give timely notice and provide the statement when requested. The IRS then issued formal guidance (including Notice 2025-15) explaining how to operationalize that option.

Translation: the IRS basically said, “Yes, you can do thisbut do it in a specific way that people can actually find and use.”

So What Is the “New ACA Reporting Option”?

The new option is best understood as “post a website Notice of Availability and furnish upon request.”

Instead of automatically sending Form 1095-B or Form 1095-C to every applicable person, an employer (or coverage provider) may satisfy the furnishing requirement by doing three things:

1. Post a clear, conspicuous, and accessible notice on a website that tells individuals they can request a copy of their ACA statement.
2. Keep that notice available for a defined period (more on the “through October 15” requirement below).
3. Provide the statement promptly when requestedgenerally within 30 days, subject to timing rules.

This isn’t permission to “ghost” your workforce. It’s permission to stop auto-mailing forms while still guaranteeing access for anyone who needs one for taxes, state filing, verification, or peace of mind.

Who Benefits (and What Still Must Be Done)

Employers (especially Applicable Large Employers)

If you’re an Applicable Large Employer (ALE)generally 50+ full-time employees (including full-time equivalents)you’re familiar with Form 1095-C and the annual ritual of line 14/15/16 codes. The IRS guidance makes the “notice + request” approach workable for Form 1095-C furnishing, which can reduce printing, postage, returned mail, and the classic “This form looks scary so I threw it away” cycle.

Plan sponsors and coverage providers issuing Form 1095-B

Entities responsible for Form 1095-B may also use the alternative furnishing approach by meeting notice and request rules. This is especially relevant for self-insured plans and other coverage providers that previously mailed forms to huge populations even when the form wasn’t needed for federal tax filing.

What does NOT change

Let’s be crystal clear (the IRS definitely is):

• You still have to file ACA returns with the IRS. This option is about furnishing to individuals, not skipping federal reporting.
• You still must be able to produce the form quickly when requested. If your data pipeline is messy, the notice option can backfire fast.
• Other ACA-related rules still apply. Employer mandate exposure, coding accuracy, and penalty processes don’t magically vanish.

How to Implement the Option Without Creating Employee Confusion

Here’s the implementation mindset: you are trading mass distribution for fast fulfillment. That’s a good tradeif you plan it.

Step 1: Choose where the notice will live

Pick a web location that is “reasonably accessible.” In real life, that means:

• Your benefits portal or HR site (ideal)
• A public-facing page if you need access for former employees
• A “Tax Information” link on the homepage that points directly to the notice

Pro tip: if someone has to click through six menus and solve a riddle, it’s not “accessible.” It’s a scavenger hunt.

Step 2: Write the notice like a human

The notice should be plain, obvious, and unmistakably about health coverage tax forms. Make it easy for people to identify and request the right statement.

At minimum, your notice should include:

• A clear statement that the individual can request a copy of their Form 1095-B or Form 1095-C
• An email address for requests
• A physical mailing address for requests
• A telephone number for questions

Step 3: Build a request process that won’t melt down in February

You need a defined workflow:

• Who receives requests (HR? payroll? a vendor?)
• How you verify identity (especially for former employees)
• How you log dates so you can prove timeliness
• How you deliver: mail, secure portal, or email with affirmative consent

Think of it like a help desk ticket systembut for tax forms and with less room for improvisation.

Deadlines, Timing, and the “Don’t Forget October 15” Rule

The guidance ties timing to the standard furnishing deadlines (including the automatic extension that often pushes furnishing into early March).

Posting deadline

Generally, the notice must be posted by the due date for furnishing the statement (including the automatic extension). For example:

• For 2024 statements (furnished in 2025), the posting deadline was March 3, 2025.
• For 2025 statements (furnished in 2026), guidance commonly points to a posting deadline of March 2, 2026.

Retention period (the “October rule”)

The notice isn’t a one-day pop-up. It must generally remain available through October 15 of the year following the calendar year to which the statement relates. In other words, keep it up through the extended tax filing season. People request forms late. It happens.

Furnishing upon request

When someone requests their statement, you must provide it by the later of:

• January 31 of the year after the calendar year the form relates to, or
• 30 days after the date of the request

Example: if an employee requests a copy of their 2024 Form 1095-C in July 2025, you generally have 30 days to furnish it. That’s not “whenever we get around to it.” That’s “put it in the queue today.”

State Mandates: The Plot Twist Employers Can’t Ignore

Federal rules are only half the story. Several states and jurisdictions have their own health coverage reporting and/or individual mandate frameworks. Depending on the state, employees may need documentation for state taxes even if their federal return doesn’t require proof of coverage.

What does that mean for employers?

• You may be legally allowed to use the IRS “notice + request” method federally, but still choose broader distribution to support state compliance and reduce employee friction.
• You might need to coordinate with vendors who handle state reporting or state-specific forms.
• Your internal communications should mention that coverage documents may be needed for state filings.

The practical approach: if you have a national workforce, treat the notice option as a toolnot a reflex. Sometimes the best compliance move is still proactive furnishing for certain populations.

A Practical Checklist (Plus Sample Notice Language)

Quick compliance checklist

• ✅ Confirm whether your organization furnishes Forms 1095-B, 1095-C, or both
• ✅ Decide whether you will adopt request-based furnishing for all eligible groups
• ✅ Draft notice content with required contact details
• ✅ Post it on an accessible webpage by the furnishing deadline (including extension)
• ✅ Keep it posted through October 15 of the relevant filing season
• ✅ Build a documented request intake + tracking process
• ✅ Ensure delivery method complies with electronic consent requirements
• ✅ Train HR/payroll staff on how to respond (and what not to promise)

Sample Notice of Availability (editable template)

IMPORTANT HEALTH COVERAGE TAX DOCUMENTS

You may request a copy of your health coverage statement (Form 1095-B and/or Form 1095-C), if applicable. To request a copy, please contact us using one of the methods below:

• Email: [email protected]
• Mail: Benefits Department, 123 Main Street, Suite 400, Anytown, ST 12345
• Phone: (555) 555-1234

Upon request, we will furnish your statement within the time required by law.

Note: This is a general template. Many employers add identity verification steps (especially for former employees) and clarify which years/forms are available.

Common Pitfalls (and How to Avoid Them)

Pitfall #1: Posting the notice… where nobody will ever see it

A notice buried in a PDF library is not “clear and conspicuous.” Put it in a place that makes sense: a tax documents page, a benefits page, or a homepage link that screams “Tax Info.”

Pitfall #2: No request tracking

If you can’t prove when the request came in and when you responded, you’re relying on vibes as your compliance strategy. Vibes are not audit-proof.

Pitfall #3: Electronic delivery without consent

Even if your workforce is digital-first, don’t assume email delivery is always allowed. Build consent into onboarding or your benefits portal and keep records.

Pitfall #4: Forgetting former employees exist

They do. And they will request forms. Make sure your notice and process are accessible to people who no longer have active portal credentials.

How This Fits With Other ACA Reporting Improvements

The “notice + request” option is the headline, but the late-2024 reporting changes came as a package. Other changes that matter to employers include:

• TIN flexibility for dependents: allowing use of a dependent’s full name and date of birth when a TIN can’t be obtained (helpful for dependent privacy and data challenges).
• Codified electronic delivery rules: recognizing prior affirmative consent for electronic delivery, as long as the person hasn’t revoked it.
• More time to respond to employer mandate penalty letters: requiring at least 90 days to respond after the IRS issues the first proposed assessment letter.
• A statute of limitations for employer shared responsibility payments: creating more certainty about the assessment time horizon.

In other words: the IRS and Congress aren’t removing ACA reportingthey’re trying to make it less like assembling IKEA furniture with missing screws.

Experiences Related to the Topic (Composite Stories From the Real World)

The following experiences are composite examples based on common employer scenarios and recurring implementation issuesnot a description of any one specific organization.

Experience 1: The “We Saved Postage” Moment (and the Surprise July Request)
A mid-sized employer with around 1,200 employees decided to adopt the notice-based approach for furnishing Form 1095-C. Their first win was immediate and measurable: fewer printed packets, fewer returned envelopes, and a smaller February workload for the mailroom and HR team. Everyone celebratedquietlybecause nothing in compliance is allowed to feel too festive.

Then July happened. A former employee emailed requesting a copy of their 1095-C for a prior year because they were dealing with a state tax notice and needed proof of coverage. The employer’s process workedbecause they had built it to handle exactly this. The request landed in a tracked inbox, a ticket was opened, identity was verified using a standard checklist, and the form was delivered within the 30-day window. The key lesson: the notice option doesn’t remove work; it redistributes work across the year. If you plan for that, it’s a smoother ride. If you don’t, July becomes “February, but with worse vibes.”

Experience 2: The “Our Portal Is Great… for Current Employees” Problem
Another employer went all-in on a slick internal benefits portal. Posting the notice was easy. Requests from active employees were easy. But within days, they realized a major gap: former employees couldn’t access the portal, and the only place the notice existed was behind login credentials. That’s not helpful when someone needs a form after terminationwhich is, ironically, when requests are most likely.

The fix wasn’t complicated, but it required coordination. They created a public-facing page with the same Notice of Availability, added a phone line and a mailing address for people who didn’t want to email personal information, and trained HR staff on a standard script: what can be shared, what verification is needed, and how long fulfillment takes. This employer’s big takeaway was that “accessible” must be interpreted like a real person interprets it, not how a project plan interprets it.

Experience 3: Vendor CoordinationAKA “The Form Is in the System, But Which System?”
A national employer with multiple payroll entities and a third-party ACA reporting vendor learned the hard way that a notice-based strategy requires airtight ownership. An employee requested their form; HR forwarded the request to the vendor; the vendor asked which EIN and which reporting entity; HR asked payroll; payroll asked finance; finance asked if this employee was actually full-time for that month; and by the time everyone agreed on the right record, the request was older than most leftover Halloween candy.

The employer didn’t miss the deadline, but the experience was… educational. They built a better intake form for requests (year needed, last known address, last four of SSN, and which subsidiary employed them), plus an internal escalation map: who answers “Which EIN?” and who answers “Which coverage tier?” They also set a goal to fulfill requests in 10 business days even though the legal timeline is longerbecause speed reduces repeated follow-ups, and repeated follow-ups are where mistakes breed.

Experience 4: Communication Strategy Matters More Than You Think
One employer assumed employees would understand the change. They posted the notice and called it a day. In late January and early February, HR was flooded with messages that boiled down to: “Where’s my form?” Not because employees were doing anything wrong, but because they had been conditioned for years to expect an automatic delivery.

The employer’s best move was a simple one: they added a short, friendly explainer in the January benefits newsletter and in the payroll system banner. It said, in plain language, that the form is available on request, why the change happened, and exactly how to request it. Requests dropped, confusion dropped, and HR regained the ability to finish a sentence without being interrupted by the words “1095” and “urgent.”

Experience 5: State Taxes Turn the “Optional” Into “Operationally Necessary”
Employers with significant populations in states with individual coverage requirements found a nuance: even if federal rules allow request-based furnishing, employees may need documentation for state filing. In those cases, some employers chose a hybrid approachrequest-based as the default, but proactive distribution to employees in certain jurisdictions or those who opted-in during open enrollment. The lesson here is strategic: compliance is not only about what’s permitted; it’s also about what reduces risk and friction for your population.

In practice, the most successful implementations treated the IRS option as a flexible tool. They used it to reduce waste and cost, but paired it with communication, tracking, vendor alignment, and a realistic understanding that people request documents at inconvenient timesusually when the person who knows the process is on vacation.

Bottom Line

The IRS guidance on the new ACA reporting option gives employers and coverage providers a practical way to reduce automatic mass distribution of Forms 1095-B and 1095-Cwithout blocking access for people who truly need them. The win is real: less paper, fewer mailed forms, fewer misdelivered envelopes. But the responsibility is also real: your notice must be easy to find, and your request process must be fast, trackable, and consistently executed.

If you implement the option thoughtfully, you’ll save time and money while improving the experience for the people who actually need their statements. If you implement it carelessly, you’ll reinvent the same workloadjust spread out, louder, and with more emails titled “URGENT.”