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Warner Norcross + Judd LLP is a corporate law firm with over 230 attorneys serving clients in nine offices throughout Michigan. Among the largest law firms in Michigan, Warner works in virtually all areas of business law.

Michigan Law Firm - Warner Norcross + Judd LLP

At the end of last year, <a href="https://www.wnj.com/updates/president-gifts-employers-a-little-aca-reporting-relief/">we told you about new legislation</a> that provides employers with a little Affordable Care Act (ACA) reporting relief. Specifically, under the Paperwork Burden Reduction Act, applicable large employers (ALEs) no longer need to automatically provide a copy of Form 1095-C to employees. Instead, ALEs only need to inform employees of their ability to request a copy of their 1095-C via a “clear and conspicuous notice.” At the time, we did not have guidance on what would be considered a “clear and conspicuous notice” or how to provide it. But now we do, with the IRS’ recent release of <a href="https://www.irs.gov/pub/irs-drop/n-25-15.pdf">Notice 2025-15</a> (the “Notice”).

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The Notice states that instead of automatically providing Form 1095-C to employees, ALEs may post a notice on its website informing employees of their ability to request a copy of their 1095-C, provided that the following conditions are met:

The notice must be reasonably accessible to all individuals for whom the ALE files a 1095-C, including current employees, former employees such as COBRA enrollees and retirees.

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The notice must include an email address, a physical address and phone number where individuals can request a copy of their Form 1095-C or seek assistance with any questions.

The notice must be written in plain, non-technical terms and with letters of a font size large enough to call attention to the fact that the information pertains to Form 1095-C.

The notice must be posted by the Form 1095-C due date for providing the form, including the automatic 30-day extension. For 2024 forms, that date is March 3, 2025.

The notice must remain on the website through Oct. 15 of the year following the year which the Form 1095-C relates. For 2024 forms, that date is Oct.15, 2025.

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The Notice refers to the following example as a compliant notice:

The ALE includes a link titled “Tax Information” on its main webpage that direct users to a secondary page. The secondary page prominently displays, in capital letters, “IMPORTANT HEALTH COVERAGE TAX DOCUMENTS,” provides instructions on how employees may request a copy of Form 1095-C and includes the ALE’s email address, mailing address and phone number.

Additionally, the Notice states that an ALE must furnish a copy of Form 1095-C within 30 days of the employee’s request. The ALE may furnish the Form 1095-C electronically, if the employee consented to it.

ALEs are still required to file Forms 1094-C and 1095-C with the IRS by March 31, 2025, if filing electronically. The due date is Feb. 28, 2025, if filing by paper. An ALE who wishes to avoid the cost of printing and mailing Form 1095-C to employees should consider posting a statement on its website that meets the requirements described in Notice 2025-15. Employers who may be subject to state-level health insurance coverage reporting — such as California’s — should review the applicable state’s filing and distribution requirements, as the new relief only applies to Forms 1095-C at the federal level.

For more information on this new IRS guidance or your ACA reporting obligations, please reach out to Stephanie Grant or a member of Warner’s Employee Benefits Practice Group.

Senior Counsel

Stephanie H. Grant

Employee Benefits

IRS Releases ACA Reporting Relief Guidance

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IRS Releases ACA Reporting Relief Guidance

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