1095-B vs. 1095-C Forms: What Brokers Need to Know for 2025

As the annual Affordable Care Act (ACA) reporting deadlines approach, it's crucial for brokers to understand the distinctions between Forms 1095-B and 1095-C to ensure accurate compliance. These forms play a key role in determining whether employers and individuals meet ACA coverage requirements, and missing deadlines can result in costly penalties.
Let’s dive into what brokers need to know about 1095-B and 1095-C for 2025.

What Is Form 1095-B?

Form 1095-B is used by health insurance providers to report individuals' minimum essential coverage (MEC) to both the IRS and the insured individuals. Form 1095-B includes details of the coverage provided, names of covered individuals and their taxpayer identification numbers (TINs), and the months of coverage for each individual to verify that individuals had health coverage throughout the year. 

This form is typically filed by:

• Insurance companies offering fully insured employer-sponsored plans
• Government programs such as Medicaid, Medicare Part A, and CHIP
• Small employers (fewer than 50 full-time employees) with self-insured health plans

The form includes details such as the type of coverage provided, the individuals covered (including dependents), and the duration of coverage. Recipients use this information when filing their tax returns to confirm they met the individual mandate, but they no longer automatically receive this form.  

What Is Form 1095-C?

Applicable Large Employers (ALEs)—those with 50 or more full-time or full-time equivalent employees—are required to file Form 1095-C for each full-time employee employed for any month of the previous year. ALEs offering self-insured plans must also report coverage information for all enrolled individuals, including non-employees (e.g., retirees, COBRA beneficiaries). 

Form 1095-C serves to:

• Detail the health insurance coverage offered to employees
• Indicate whether the coverage met ACA affordability and minimum value standards
• Help the IRS determine whether the employer is subject to the Employer Shared Responsibility Payment

Each Form 1095-C provides information about an employee’s coverage, the months it was offered, and the cost of the lowest-priced plan available to them.

ACA Reporting Deadlines for 2025

The deadlines for filing Forms 1094-B, 1095-B, 1094-C, and 1095-C with the IRS are:

• Paper Filing: February 28, 2025 
• Electronic Filing: March 31, 2025 

New Employer Furnishing Flexibility Under Recent Legislation

• Provide a clear, conspicuous, and accessible notice on their website informing individuals of their right to request a copy of the form.
• Furnish the form within 30 days of an individual's request or by January 31 of the following year, whichever is later.

This change reduces the administrative burden on employers and insurers while ensuring that individuals can still access their forms upon request. It's important to note that while the furnishing requirements have been relaxed, the obligation to file these forms with the IRS remains unchanged.

• Accurate submissions to the IRS
• Timely filing before deadlines
• Compliance with ACA reporting requirements

Failure to file correct information returns with the IRS or furnish correct statements when requested can result in penalties. Need help with ACA filing? Speak to a product specialist today!

And, to ensure you’re covering all your bases, download our Q1 Broker Checklist.

Additional Resources

• Brokers’ Corner Podcast—watch and subscribe to the Brokers’ Corner podcast, which dives into the topics that affect your agency and industry and identifies strategies so you can protect and grow your book of business 
• BerniePortal Brokers’ Council—a council of benefits brokers from across the country that advises BerniePortal on industry concerns, trends, and the ways technology can best support their agency and employer groups 
• BerniePortal for Brokers—leveraging technology to increase your agency valuation and support your employer groups is easier than ever with BerniePortal’s software solution, built for brokers by brokers