The Internal Revenue Service (IRS) has released draft instructions for Affordable Care Act (ACA)-required reporting of offers of employee health insurance coverage and employee enrollment in health insurance coverage. The instructions will be for Forms 1094-C and 1095-C.

The draft instructions specify that “employers no longer have to automatically send Form 1095-C to individuals. The requirement for furnishing the statement is met if the employer responsible for providing the statements provides clear, conspicuous, and accessible notice on its website   that an individual may request a copy of their statement and the copy is timely furnished. For this purpose, the statement is timely furnished if provided to the individual no later than the later of January 31, 2026, or 30 days after the date of the request. For additional guidance, see IRS.gov/irb/2025-11_IRB#NOT-2025-15.”

Generally, applicable large employers (ALEs)—those with 50 or more full-time equivalent employees—must file Forms 1094-C and 1095-C for each employee who was a full-time employee of the ALE for any month of the calendar year. This information is used by the IRS to determine an ALE’s ACA-required shared responsibility obligations.

Prospects: IRS is accepting comments on the draft instructions, which include information on where to access information on future developments. The draft instructions also contain cites to other ACA information and requirements.

NAIFA Staff Contact: Mike Hedge – Senior Director – Government Relations, at mhedge@naifa.org.