New ACA Reporting Relief for Employers Announced by IRS

New legislation under the Paperwork Burden Reduction Act provides relief for applicable large employers (ALEs) regarding the reporting of Form 1095-C under the Affordable Care Act (ACA). Instead of automatically providing this form to employees, ALEs are now only required to inform employees that they can request a copy through a clear notice. The IRS has released Notice 2025-15, which outlines the criteria for what constitutes a clear and conspicuous notice of this option.

The Notice specifies that ALEs can inform employees of their request rights by posting a notice on their website, as long as certain conditions are fulfilled. If an employee requests their Form 1095-C, the ALE must provide it within 30 days, and it can be sent electronically if the employee consents. However, ALEs still have obligations to file Forms 1094-C and 1095-C with the IRS by specific deadlines in 2025, while also considering state-level reporting requirements such as those in California.