IRS Issues ACA Reporting Guidance on Providing Statements Upon Request

The IRS has issued Notice 2025-15, providing guidance on the alternative manner of furnishing statements to covered individuals and full-time employees using Forms 1095-B and 1095-C, in accordance with the Affordable Care Act (ACA) reporting requirements.

Key Takeaways

• IRS Notice 2025-15 confirms that reporting entities can satisfy the alternative manner of furnishing statements upon request under the Paperwork Burden Reduction Act if they comply with the same alternative method that has been in effect for the past few years. However, this method only applies when the individual mandate penalty is zero.
• The IRS clarified that reporting entities can use this alternative method regardless of whether the individual mandate penalty is zero.

Background

The Paperwork Burden Reduction Act, enacted at the end of 2024 and applicable to 2025 reporting deadlines, states that reporting entities are no longer required to send Forms 1095-B and 1095-C to covered individuals and full-time employees unless the individual requests a form.

• This legislation codified an existing alternative manner of furnishing Forms 1095-B, which was originally established by a 2022 final rule, and extended it to Forms 1095-C.

Alternative Manner of Furnishing

Under the new rules, reporting entities must notify individuals of their right to request a copy of their statement “at such time and in such manner as the [IRS] may provide” to take advantage of the alternative method.

These requirements are set forth in IRS Notice 2025-15, which also applies to 2024 calendar year reporting due in early 2025.

• If an individual requests a copy of their statement, it must be fulfilled by Jan. 31 of the year following the calendar year to which the return relates or within 30 days of the request, whichever is later.

Timely Notice to Individuals

For 2024 statements required to be furnished in 2025, reporting entities can use the alternative method if they:

1. Post a clear and conspicuous notice on their website by March 3, 2025, stating that covered individuals and full-time employees may request a copy of their statement.
   • The notice must include:
     • An email address
     • A physical address where requests can be sent
     • A telephone number to contact the reporting entity
2. Keep the notice in the same location on the website through October 15, 2025.

Action Steps

Reporting entities wishing to use this alternative method must:

• Post the required notice on their website by March 3, 2025, and ensure it remains accessible until October 15, 2025.
• If they do not use this alternative method, they must provide Forms 1095-B and 1095-C to all covered individuals and full-time employees by March 3, 2025.
• Continue to comply with applicable state reporting requirements, as this alternative method only applies to federal ACA reporting.

For more details, visit the IRS publication:
IRS Notice 2025-15