Helping Your Clients Prepare for 1095-C Filing and Distribution in 2025

As the 2025 deadline for filing and distributing 1095-C forms approaches, benefits brokers play a pivotal role in guiding their clients—Applicable Large Employers (ALEs)—to remain compliant with the Affordable Care Act (ACA). This guide breaks down the essentials, deadlines, and best practices to help you assist employers through this important process while enhancing your client relationships.

What Are Forms 1094-C and 1095-C?

Under the ACA, ALEs—employers with 50 or more full-time equivalent employees—must file Forms 1094-C and 1095-C to report their health coverage information. These forms verify whether employers offered affordable, minimum essential coverage in the previous plan year and provide employees with documentation needed for tax purposes.

By understanding these requirements, benefits brokers can offer proactive support to ensure compliance and prevent costly penalties.

2025 Deadlines for Filing and Distributing Form 1095-C

• Paper submissions: February 28, 2025
• Electronic submissions: March 31, 2025 (required for 10+ forms).

Best Practices for Benefits Brokers

Benefits brokers can provide significant value by implementing these best practices:

1. Ensure Accurate Employee Information

Encourage clients to verify key details like Social Security Numbers, months of coverage, and dependent information to avoid filing errors or distribution delays.

2. Recommend Efficient Filing Methods

Electronic submission is mandatory for clients filing 10 or more forms. Introduce them to approved e-filing software or IRS-certified providers to simplify and secure the process. BerniePortal can file 1094-C/1095-C forms with the IRS, and this year, we’ve added 1094-B and 1095-B filing. If you’d like to learn more, feel free to schedule a meeting with one of our product specialists!

3. Highlight Recordkeeping Requirements

Remind employers to retain copies of submitted forms and distribution records for a minimum of three years, as required by the IRS. Proper documentation ensures readiness for potential audits.

Key Considerations for IRS Filing

Electronic filing is mandatory for clients submitting 10 or more forms. This requirement applies to many types of forms, including 1095-Cs, W-2s, 1099s, and several others. Filing electronically not only ensures compliance but also offers significant benefits such as faster processing and a reduced risk of errors.

For clients filing fewer than 10 forms via mail, it’s crucial to handle submissions carefully. Use first-class mail, flat envelopes to avoid damage, and proper labeling for bulk submissions.

Encouraging electronic filing helps streamline the process, minimizes risks, and keeps your clients ahead of IRS requirements. To learn more about e-filing and its advantages, check out this blog. 

Frequently Asked Questions You May Field from Clients

Your clients may have questions about the process. Here’s how you can respond:

What is included on Form 1095-C?

The form outlines the employer's health insurance offer, the employee's share of costs, and coverage status.

Who needs to receive Form 1095-C?

All full-time employees and individuals enrolled in the employer’s health plan must receive the form.

What happens if an employer misses the deadline?

Late filings can result in penalties from the IRS. Encourage clients to act early to avoid these risks.

Do employees need Form 1095-C to file taxes?

While not mandatory, the form helps employees verify coverage and calculate potential premium tax credits. In 2024, Applicable Large Employers (ALEs) were required to distribute Forms 1095-C to all full-time employees and file them with the IRS by this date, regardless of whether employees request them. But under the Employer Reporting Improvement Act and the Paperwork Burden Reduction Act, you’ll only need to send Forms 1095-B and 1095-C upon request. To take advantage of this change, employers must notify employees of their right to request these forms, with further guidance from the IRS expected soon.

By staying informed about ACA requirements and deadlines, you position yourself as an invaluable partner to your clients. Offer to assist with:

• Reviewing and verifying employee data.
• Identifying efficient e-filing solutions.
• Educating employers about compliance risks and how to mitigate them.

The upcoming filing season offers an excellent opportunity to strengthen client relationships while ensuring their compliance with ACA mandates.

Additional information is available on the IRS’s official website under ACA compliance resources. 

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