Employer Guide & Glossary
ACA REPORTING: IRS FORMs 1095-B & C
The key IRS forms for ACA reporting are FORM 1094-B & C and FORMS 1095-B & C.
FORMS 1095-B & C are employee forms and FORM 1094-B & C is an employer form. You can find IRS DEADLINES for completing and e-filing these forms to the IRS here.
FORM 1095-B
This IRS employee form is the responsibility of HEALTH COVER PROVIDERS — in other words, the insurance company [or other entities, including self-insured employers] paying the medical bills.
Self-insured employers must distribute or make this form available to every covered employee detailing their coverage and thereby enabling them to report their own individual ACA compliance to the IRS.
FORM 1095-B includes information on all dependents & other individuals covered by a policy in addition to the employee as policy holder. It enables the IRS to determine who has MINIMUM ESSENTIAL COVERAGE & therefore is not liable for an individual shared responsibility payment.
FORM 1095-C
This IRS employee FORM 1095-C is the responsibility of the employer as the health coverage sponsor to complete and distribute or make available to every full-time employee.
As part of their ACA reporting & compliance, APPLICABLE LARGE EMPLOYERS [ALEs] must send completed FORMS 1095-C to every eligible employee, detailing the offer of coverage they have received under the company’s sponsored plan. These forms are subsequently also filed by the employer [along with other required documentation] to the IRS.
SELF-EMPLOYED INDIVIDUALS are NOT considered W-2 employees for ACA employer mandate purposes, and no FORM 1095-C is required. SELF-EMPLOYED STATUS includes sole proprietors, partners in a partnership, and 2% S corporation shareholders.
For a comprehensive guide to the IRS CODES for completing LINES 14 & 16 of FORM 1095-C click here.
- NOTE: EMPLOYERS WITH FULLY-INSURED PLANS are the sponsor but not provider of health coverage. The health plans sponsored by these employers are provided by an insurance company. The FULLY-INSURED employer is responsible only for FORM 1095-C.
- NOTE: EMPLOYERS WITH SELF-INSURED PLANS are both sponsor & provider of health coverage. In other words, the plan is funded entirely by the employer, who pays for any employee health claims instead of an insurance company. These SELF-INSURED employer are accordingly responsible for both FORM 1095-B [as the provider] and FORM 1095-C [as the sponsor]. That said, SELF-INSURED employers can combine these forms into a single FORM 1095-C.
- NOTE: PART III OF FORM 1095-C must only to be completed by employers sponsoring self-insured health coverage; it includes, in addition to the named employee, any dependents and other individuals covered by the plan.
EASING OF FORM 1095 PAPERWORK BURDEN
On December 23, 2024, new legislation was signed affecting ACA reporting, namely, the Paperwork Burden Reduction Act [PBRA]. This act eased the burden on Applicable Large Employers [ALEs] to furnish their employees with a FORM 1095-B [self-insured employers] and/or FORM 1095-C [both self-insured and fully insured employers].
Employers are no longer required to send a physical or digital FORM 1095-B or FORM 1095-C to employees unless they request a copy.
Please Note: The PBRA does not apply changes to the FORM 1095 distribution requirements for employers in states with individual health insurance mandates.
Employers not distributing FORMS 1095 must, however, provide a “clear, conspicuous, and accessible notice” to employees informing them that they can request a copy of their form. For TY26, this form must then be sent to the employee not later than January 31, 2027 [or 30 days after the request]. "Clear, conspicuous, and accessible notice” must include a physical address, email, and telephone number where employees can make their request for a FORM 1095.
If you have questions regarding FORMs 1095-B or C or any other aspect of ACA reporting & compliance, please contact BENEFITSCAPE , the leading ACA specialist.
BENEFITSCAPE provides best-in-class ACA COMPLIANCE SERVICES, including intelligent, system-agnostic ACA_RegTech, to 1000s of employers of all sizes, in all sectors, across all states, and on all major Payroll and HCM systems.