In Notice 2025-15, the IRS clarifies how to comply with the new requirements for furnishing Forms 1095-C, Employer-Provided Health Insurance Offer and Coverage, by using the alternative method as allowed in the Paperwork Burden Reduction Act.

Notice 2025-15 is effective for returns for calendar years beginning after 2023.

Background

The Paperwork Burden Reduction Act (H.R. 3797) amended IRC Sections 6055(c) and 6056(c) to allow an alternative method of furnishing Forms 1095-B and 1095-C (see Tax Alert 2025-0103). Under this Act, reporting entities do not need to send forms to individuals so long as the entity posts a notice prominently on their website that individuals may receive their form upon request. If requested by the participant, the form must be furnished by the earlier of (1) January 31 of the year following the calendar year for which the return was required to be made or (2) 30 days after the request. The posted notice must be available by the due date for furnishing the statement, which for 2024 is March 3, 2025.

IRC Section 6055 requires health insurance issuers, self-insuring employers, government agencies and other providers to furnish and file annual information returns and statements on the coverage provided to their employees and other individuals. IRC Section 6056 imposes a similar requirement on applicable large employers (ALEs). Form 1095-B meets the requirements of the IRC Section 6055 regulations. Form 1095-C meets the requirements of the IRC Section 6056 regulations. Before the Act, physical or electronic versions of these returns were required to be sent to each intended recipient.

Clarifications

According to Notice 2025-15, entities that are required to furnish Form 1095-B and ALEs that are required to furnish Form 1095-C may use the alternative method of furnishing regardless of the amount of premiums (including zero) paid by the individuals.

Treas. Reg. Section 1.6055-1(g)(4)(ii)(B) gives specific instructions on how to comply with the alternative furnishing requirements. In general, to use the alternative manner of furnishing statements, the following conditions must be met:

• The employer must provide a clear and conspicuous notice, in a location on its website that is reasonably accessible to all responsible individuals, with information on how individuals may request a copy of their form upon request
• The notice must include an email address, a physical address and a telephone number where a request can be made
• The notice must be in plain, non-technical terms and visually clear
• The posted notice must be available by the due date for furnishing the statement, including the automatic 30-day extension (e.g., for 2024 statements, the notice must be posted by March 3, 2025), and stay in the same location on its website through October 15, 2025
• The employer must furnish the statement to a requesting responsible individual within 30 days of the date the request is received; to satisfy this requirement, the employer may furnish the form electronically if the recipient affirmatively consents

Implications

Employers may want to consider using the alternative manner of furnishing to reduce the cost of printing and mailing the forms; however, they will need to implement procedures, so that individuals who request forms receive them as required under the Act.

While Notice 2025-15 contemplates employers placing a notice that an individual's form is available upon request on their website, such website would need to be accessible to all intended recipients — employees, former employees and retirees.

Employers should also consider that certain states have their own requirements for furnishing forms to individuals and confirm what is required. For example, the reporting guidelines for California and the District of Columbia suggest that complying with the IRS requirement to furnish forms would satisfy the respective state's furnishing requirements, while the New Jersey and Rhode Island guidance refers to providing a written statement and does not specify that complying with the federal furnishing satisfies the state furnishing requirement. Therefore, some forms may still need to be mailed.