2025 ACA Reporting: Forms, Instructions & Deadlines

The Affordable Care Act requires applicable large employers (ALEs) – generally those with 50 or more full-time employees – to report information to the IRS and to their full-time employees about their compliance with the employer shared responsibility (pay or play) provisions and the health care coverage they have offered (or did not offer).

Self-insured employers (regardless of size) have additional reporting responsibilities that apply to health coverage providers.

2025 filing deadlines for 2024 coverage are as follows:

ACA Requirement (Fully Insured ALE’s)

Deadline

Provide Form 1095-C to Full-Time Employees

March 3, 2025*

File Forms 1094-C &1095-C with the IRS

March 3, 2025*

ACA Requirement (Self-Insured ALE’s)

Deadline

Provide Form 1095-C to Full-Time Employees

March 3, 2025*

Provide Form 1095-B to Responsible Individuals (may be the primary insured, employee, former employee, or other related person named on the application)

ALEs providing self-insured coverage to non-employees may use either Form 1095-B or Form 1095-C to report coverage for those individuals and other family members covered under the plan, by March 3, 2025.

File Forms 1094-B & 1095-B with the IRS  

ALEs providing self-insured coverage to non-employees may use either the B series Forms or the C series Forms to report coverage for those individuals and other family members covered under the plan, by March 31, 2025*

ACA Requirement
Self-Insured Employers That Are Not ALEs (Fewer Than 50 Full-Time Employees)

Deadline

Provide Form 1095-B to Responsible Individuals (may be the primary insured, employee, former employee, or other related person named on the application)

March 3, 2025, if not using the alternative method of furnishing. Under this method, a reporting entity must post a clear and conspicuous notice on its website stating that responsible individuals may receive a copy of their statement upon request.

File Forms 1094-B & 1095-B with the IRS  

March 31, 2025*

Forms & Instructions

The following Internal Revenue Service (IRS) forms and instructions are available for 2024 calendar year reporting:

Form 1094-B and Form 1095-B (and instructions)

*Beginning with 2024 calendar year reporting employers may use the alternative method of furnishing forms 1095-C to employees. Under this method, they must post a clear and conspicuous notice on their website stating that responsible individuals may receive a copy of their statement upon request.

For updated 2025 ACA reporting details you can view our ACA Reporting Guide

**Reporting entities that file at least 10 returns during the calendar year must file electronically.