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Form 1095-B & 1095-C 2025 – In the ever-evolving landscape of Affordable Care Act (ACA) compliance, Forms 1095-B and 1095-C play a crucial role in reporting health insurance coverage. These forms help the IRS track minimum essential coverage, employer offers, and eligibility for premium tax credits. Whether you’re an employer, insurer, or HR professional, understanding the 2025 updates—including deadlines, filing requirements, and key codes—is essential to avoid penalties. This comprehensive guide breaks down everything you need to know, drawing from official IRS resources to ensure accuracy and SEO-friendly insights for terms like “1095-B deadlines 2025” and “1095-C codes cheat sheet.”
What Is Form 1095-B?
Form 1095-B, titled “Health Coverage,” is used by providers of minimum essential coverage—such as health insurers, government-sponsored programs, or small employers (fewer than 50 full-time equivalents) with self-insured plans—to report information about individuals covered under their plans. This form details the months of coverage for the calendar year and is furnished to the “responsible individual” (typically the primary insured). It’s required under IRC Section 6055 to help individuals verify coverage when filing their tax returns and to assist the IRS in administering the individual shared responsibility provision.
Key users include:
- Health insurance issuers.
- Self-insured plan sponsors (non-applicable large employers or ALEs).
- Government agencies providing coverage like Medicaid or CHIP.
If you’re a small business offering self-insured health plans, this form ensures compliance without the added complexity of employer shared responsibility reporting.
What Is Form 1095-C?
Form 1095-C, “Employer-Provided Health Insurance Offer and Coverage,” is filed by applicable large employers (ALEs)—those with 50 or more full-time employees or equivalents—to report offers of coverage and enrollment details. It combines reporting under IRC Sections 6055 (coverage) and 6056 (employer offers), making it a dual-purpose form for ALEs with self-insured plans.
This form includes:
- Employee details and months of full-time status.
- Offers of minimum essential coverage (MEC) that meets minimum value and affordability standards.
- Enrollment in employer-sponsored plans.
ALEs must furnish this to full-time employees, while non-ALEs use Form 1095-B for self-insured reporting. For 2025, the affordability threshold is 9.02% of household income for the lowest-cost self-only plan.
Key Deadlines for 2025 Reporting
Reporting for calendar year 2025 coverage occurs in 2026. Here’s a breakdown of the critical dates:
| Deadline Type | Date | Details |
|---|---|---|
| Furnish to Individuals | March 2, 2026 | Provide Form 1095-B to responsible individuals or Form 1095-C to full-time employees. This is a business day adjustment since March 1 falls on a Sunday. |
| File with IRS (Paper) | March 2, 2026 | Submit Forms 1094-B/1095-B or 1094-C/1095-C via mail. |
| File with IRS (Electronic) | March 31, 2026 | Mandatory for filers with 10 or more returns (aggregated across all form types like W-2s and 1099s). |
New Alternative Furnishing Method
Thanks to the Paperwork Burden Reduction Act, employers and providers can now opt out of automatic distribution. Instead, post a clear, conspicuous notice on your public website by January 31, 2026, informing individuals how to request their form. You must furnish the form within 30 days of the request (or by January 31, whichever is later) and keep the notice posted until October 15, 2026. This doesn’t apply to New Jersey residents, who require proactive delivery.
Extensions may be requested using Form 8809, but automatic 30-day extensions for furnishing are permanent under updated regulations.
Filing Requirements for Forms 1095-B and 1095-C
Compliance starts with knowing who must file and how:
- Who Must File 1095-B? Insurers, self-insured non-ALEs, and government programs providing MEC. If you’re an ALE with self-insured plans, use Form 1095-C instead for combined reporting.
- Who Must File 1095-C? All ALEs, regardless of plan type (fully insured or self-insured). Government employers and those with individual coverage HRAs (ICHRAs) also qualify.
- Electronic Filing Threshold: If you file 10+ information returns total in a year, e-file via the ACA Information Returns (AIR) system. Obtain a Transmitter Control Code (TCC) if new to filing.
- Corrections: Use a corrected form with the “CORRECTED” box checked. Submit to the IRS with a non-authoritative transmittal and furnish to individuals.
- Penalties for Non-Compliance: Up to $330 per return for failure to file or furnish (2025 inflation-adjusted amounts apply).
For ICHRAs, affordability is determined using ZIP code safe harbors (primary residence or employment site). No major form changes for 2025, but ensure software uses the TY2025 schema.
Codes Cheat Sheet for Form 1095-C
Form 1095-C uses specific codes on lines 14 and 16 to report offers and relief. Here’s a quick reference table based on IRS instructions.
Line 14: Offer of Coverage Codes
| Code | Description |
|---|---|
| 1A | Qualifying Offer: MEC with minimum value, employee contribution ≤9.02% of federal poverty line, coverage to spouse/dependents. |
| 1B | MEC with minimum value to employee only. |
| 1C | MEC with minimum value to employee and dependents (not spouse). |
| 1D | MEC with minimum value to employee and spouse (not dependents). |
| 1E | MEC with minimum value to employee, spouse, and dependents. |
| 1F | MEC without minimum value to employee, spouse, or dependents. |
| 1G | Coverage to non-employee or non-full-time employee enrolled in self-insured plan. |
| 1H | No offer of coverage. |
| 1I | Reserved. |
| 1J | MEC with minimum value to employee; conditional to spouse; none to dependents. |
| 1K | MEC with minimum value to employee and dependents; conditional to spouse. |
| 1L | ICHRA to employee only (residence ZIP affordability). |
| 1M | ICHRA to employee and dependents (not spouse, residence ZIP). |
| 1N | ICHRA to employee, spouse, and dependents (residence ZIP). |
| 1O | ICHRA to employee only (employment site ZIP). |
| 1P | ICHRA to employee and dependents (not spouse, employment site ZIP). |
| 1Q | ICHRA to employee, spouse, and dependents (employment site ZIP). |
| 1R | Non-affordable ICHRA to employee, spouse, or dependents. |
| 1S | ICHRA to non-full-time employee. |
| 1T | ICHRA to employee and spouse (not dependents, residence ZIP). |
| 1U | ICHRA to employee and spouse (not dependents, employment site ZIP). |
| 1V-1Z | Reserved for future use. |
Line 16: Section 4980H Safe Harbor and Other Relief Codes
| Code | Description |
|---|---|
| 2A | Employee not employed. |
| 2B | Employee not full-time. |
| 2C | Employee enrolled in offered coverage. |
| 2D | Limited non-assessment period. |
| 2E | Multiemployer interim relief. |
| 2F | W-2 safe harbor. |
| 2G | Federal poverty line safe harbor. |
| 2H | Rate of pay safe harbor. |
| 2I | Reserved. |
Codes Cheat Sheet for Form 1095-B
Form 1095-B uses codes primarily in Part I, line 8, for the origin of the policy. These help classify the type of coverage provided.
| Code | Description | |
|---|---|---|
| A | Small Business Health Options Program (SHOP). | |
| B | Employer-sponsored coverage (not SHOP). | |
| C | Government-sponsored program (not Medicaid, Medicare, or TRICARE). | |
| D | Medicaid. | |
| E | Medicare Part A or C. | |
| F | CHIP. | |
| G | TRICARE. | |
| H | Individual coverage HRA (ICHRA). | Note: Use these to accurately report the source of MEC. |
Conclusion: Staying Compliant with 1095-B and 1095-C in 2025
Navigating ACA reporting can be complex, but adhering to these deadlines, requirements, and codes ensures smooth compliance. With no major form changes for 2025 but new flexibility in furnishing, now’s the time to review your processes. Consult IRS Publication 5223 for e-filing specs or a tax professional for personalized advice. By optimizing your approach, you can minimize risks and focus on providing quality health benefits. For more on “1095-C requirements 2025” or related queries, check official IRS updates regularly.