Mass mailings — no more. As a reminder, because of the Paperwork Burden Reduction Act, Applicable Large Employers (ALEs) are no longer required to automatically furnish Form 1095-C to applicable individuals, provided they post a “clear and conspicuous” notice on their website informing the individuals that they may receive a copy of the form upon request. To rely on this website notice method, an ALE must satisfy several requirements, as described in IRS Notice 2025-15:
Format
- The notice must be written in plain, nontechnical language and use a font size large enough to draw attention to the fact that the information relates to health coverage tax reporting.
Location
- The notice must be in a location on the website that is reasonably accessible to all applicable individuals, including current employees and former employees, such as COBRA enrollees and retirees.
- For example, posting the notice only on an internal employee intranet that requires active employee credentials would not be “reasonably accessible.”
Timing
- The notice must be posted by March 2, 2026, and must remain on the website until Oct. 15, 2026.
Delivery
- Upon request by an individual, an ALE must deliver the Form 1095-C to the individual within 30 days or, if later, by Jan. 31 of the year following the year to which the Form 1095-C relates.
- Electronic delivery is permitted if the individual consents.
Next Steps
ALEs are still required to file Forms 1094-C and 1095-C with the IRS by March 31, 2026, if filing electronically. An ALE who wishes to avoid the cost of printing and mailing Form 1095-C to individuals should consider posting a statement on its website that meets the requirements described in IRS Notice 2025-15. Employers who may be subject to state-level health insurance coverage reporting should review the applicable state’s filing and distribution requirements.
For more information on this IRS guidance or your ACA reporting obligations, please reach out to Stephanie Grant, Cade Bunton or a member of Warner’s Employee Benefits Practice Group.
