2025 ACA Reporting Forms & Instructions Have Been Finalized — What Employers Need to Know

No major structural changes — but the alternative furnishing method carries deadlines that are easy to miss.

The IRS has officially released the final 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.

There are no major structural changes to the forms themselves — but there are important reminders and clarifications employers should not overlook.

Which forms apply

• Forms 1094-B and 1095-B — used by providers of minimum essential coverage, including self-insured employers that are not Applicable Large Employers, to satisfy Section 6055 reporting.
• Forms 1094-C and 1095-C — used by Applicable Large Employers to comply with Section 6056. ALEs sponsoring self-insured plans continue to use these forms for combined reporting under both sections.

The alternative furnishing method

The most significant clarification, carried forward from prior years, is the continued allowance of the alternative furnishing method for Forms 1095-B and 1095-C. Employers are no longer required to automatically mail these forms to individuals. Instead, the furnishing requirement can be satisfied by posting a clear website notice informing individuals they may request a copy.

To remain compliant, that 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 to take now

1. Review the finalized 2025 forms and instructions carefully.
2. Confirm whether you qualify as an ALE and which forms apply.
3. Evaluate electronic filing options, including third-party ACA reporting vendors.
4. Ensure internal systems and payroll and 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. Even without major form changes, ACA reporting remains complex and detail-driven, and reporting errors carry real penalty exposure.