Final ACA Reporting Forms and Instructions for 2025 Calendar Year

1/16/2026

The IRS has released final Affordable Care Act (ACA) information reporting forms and instructions for the 2025 calendar year.  Form 1095-C or 1095-B is used to report information about each employee.  Form 1094-C or 1094-B is used to report to the IRS summary information for each employer and to transmit Forms 1095-C or 1095-B to the IRS.

Applicable Large Employers (ALEs) must file Form 1094-C with the IRS no later than March 31st of each year, if filing electronically.  ALEs, generally, are employers with 50 or more full-time employees (including full-time equivalent employees) in the previous year.  Employers with fewer than 50 employees will file Form 1094-B with the IRS.  If filing by paper, which is permitted only for employers who must file fewer than 10 returns, employers must file no later than February 28th/29th of each year.  Employers must still send Forms 1095 to the IRS, even though they are required to send these forms to employees only upon request.

Here are the important deadlines for filing 2025 information:

  • March 31, 2026: deadline for filing Form 1094-C or 1094-B transmittal (and copies of related Forms 1095-C or 1095-B) with the IRS, if filing electronically.  Electronic filing is mandatory if the ALE is required to file 10 or more forms for the 2025 calendar year.
  • March 2, 2026: deadline for filing Form 1094-C or 1094-B transmittal (and copies of related Forms 1095-C or 1095-B) with the IRS, if filing on paper.  Paper filing is allowed if the employer is required to file fewer than 10 forms for the 2025 calendar year.

Note: employees have a right to request a Form-1095, and in that case, the Form-1095 must be provided by the later of January 31, 2026 or 30 days after the date of the request.

If you have questions on the ACA reporting requirement, call ASR Health Benefits at (616) 957-1751 or (800) 968-2449.