Dec.16, 2025

ACA Reporting Requirements for Plan Year 2025: Key Points and Deadlines

By Drema K. Foster

The Affordable Care Act (ACA) mandates specific reporting requirements for applicable large employers (ALEs), generally those with 50 or more full-time equivalent (FTE) employees, as well as self-insured employers of any size. For plan year 2025, the reporting process for employer-provided health coverage is largely unchanged and deadlines remain crucial. The Paperwork Burden Reduction Act expands employer’s options for delivering ACA forms to employees. Below is a brief summary of the 2025 ACA reporting requirements and deadlines:

Who is Required to File

Under Section 6056 of the Internal Revenue Code, an Applicable Large Employer (ALE) must report information on Form 1095-C that discloses if an employer is subject to an assessment of a Shared Responsibility Payment. Generally, an ALE is an employer with fifty (50) or more full-time equivalent (FTE) employees during the previous calendar year. This may include employers that are part of an aggregated ALE group due to significant common ownership or control stemming from related employer entities. If you are unsure whether your organization is an ALE, contact us to discuss.

• The ACA requires Applicable Large Employers (ALEs) to report whether they offered minimum essential coverage (MEC) that was affordable and provided minimum value to full-time employees.
• Employers of any size with self-insured plans (including level-funded) also report months of coverage for all individuals.
• ACA reporting for fully insured ALEs is handled via IRS Forms 1094-C and 1095-C. Self-insured employers, regardless of size, must complete and submit Forms 1095-B and 1094-B for reporting minimum essential coverage (MEC).

Plan Year 2025 ACA Reporting Deadlines

The IRS has updated reporting deadlines as follows:

• Employee Form Distribution: Forms 1095-B and 1095-C must be distributed to employees by March 2, 2026.
• IRS Filing: Employers filing 10 or more returns (this number includes 1095 forms, W-2, and 1099 forms) must file electronically by March 31, 2026.

New Options – Beginning with 2025 coverage (forms furnished in early 2026):

ALEs may use the alternative furnishing method for Form 1095-C. This means:

• ALEs are no longer required to automatically mail Form 1095-C to every full-time employee.
• Instead, the employer may:
  1. Post a clear and prominent notice on its website stating that Form 1095-C is available upon request. (We can provide you with sample language)
  2. Provide instructions for how individuals may request their form (email, phone, or mailing address).
  3. Keep the notice posted through at least October 15, 2026.
  4. Furnish the Form 1095-C within 30 days of receiving any request.

This option applies to all ALEs, regardless of whether their health plan is fully insured or self-insured.

Penalties for Reporting Non-Compliance

Employers that fail to file electronically when required, miss reporting deadlines, or submit inaccurate information may incur penalties. Meeting the ACA’s reporting requirements is critical for ALEs and self-insured employers.

If Suttle & Stalnaker prepared your plan year 2024 1095-C forms, we will be sending you the 2025 engagement letter and data template in the coming week.

Our HR Consulting team has the knowledge and expertise to help you, and your business navigate the Affordable Care Act (ACA) reporting complexities. Please contact our office if you need assistance with reporting or if you have other ACA related questions or concerns.