The Internal Revenue Service has released the 2025 instructions for Forms 1094-B and 1095-B (health coverage reporting) and Forms 1094-C and 1095-C (applicable large employer reporting). These forms are used by providers of minimum essential coverage and applicable large employers to report coverage information to the IRS and covered individuals.
The most significant change makes the alternative method for furnishing statements to individuals available to all filers of Forms 1095-B and 1095-C. Beginning with tax year 2024 reporting, employers are no longer required to automatically send Forms 1095-B and 1095-C to individuals. Instead, employers may satisfy the furnishing requirement by posting clear, conspicuous notice on their website that individuals may request a copy of their statement. The notice must include contact information and be posted by March 2, 2026, and retained through October 15, 2026. Statements must be furnished no later than the later of January 31, 2026, or 30 days after the request date. This optional alternative is detailed in Notice 2025-15.
The instructions also update filing and furnishing deadlines for the 2025 tax year. Forms filed on paper must be submitted by March 2, 2026 (or March 31, 2026 if filing electronically). Additionally, penalty amounts for failures to file or furnish correct forms increased from $330 to $340 per return, with annual maximum penalties rising from $3,987,000 to $4,098,500. The intentional disregard penalty increased from $660 to $680 per return.
The 2025 Instructions for Forms 1094-B and 1095-B can be found here.
The 2025 Instructions for Forms 1094-C and 1095-C can be found here.
