The Affordable Care Act (ACA) reporting season for the 2025 tax year is approaching quickly. The IRS has issued final versions of Forms 1094-C (Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns) and 1095-C (Employer-Provided Health Insurance Offer and Coverage), along with the accompanying instructions.
As a reminder, Applicable Large Employers (ALEs), those with 50 or more full-time employees, including full-time equivalents (FTEs), are required to file these forms under Internal Revenue Code §6056. This reporting provides the IRS with the information needed to administer employer shared responsibility provisions and determine eligibility for premium tax credits.
Key Updates for 2025
The 2025 forms remain largely unchanged. However, the instructions now reflect the updated affordability safe harbor and qualifying offer method percentage, which is 9.02% for 2025.
Please access the finalized IRS resources below:
Who Must Report?
Under the ACA, all ALEs must use Forms 1094-C and 1095-C to report their compliance with the employer shared responsibility (“pay or play”) provisions, as well as the health coverage offered to their employees. Employers that are self-insured and have 50 or more full-time employees, including full-time equivalents (FTEs), must also use these same C Forms to fulfill their minimum essential coverage reporting requirements.
What Are the Deadlines?
Deadline for Furnishing Statements to Individuals
Employers must furnish Forms 1095-C to individuals by March 2, 2026, upon employee request.
Deadlines for Filing Returns With the IRS
Employers must file Forms 1094-C with the IRS by the following dates:
February 28, 2026, for paper filing
March 31, 2026, for electronically filing
Filers may request an extension of these deadlines by submitting Form 8809 to the IRS.
How Will MedCost Assist?
MedCost will generate ACA reporting data and make reports available to our clients as early as the week of December 15, 2025. These reports will be posted to the secure Employers Portal on our website.
Additional details, including instructions for accessing and using the reports, will be provided in a future communication.
As always, MedCost is committed to supporting you with your ACA reporting requirements. If you have any questions or need further assistance, please contact your MedCost Account Manager or the Compliance Department at [email protected].