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.
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.
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.
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.
Your clients may have questions about the process. Here’s how you can respond:
The form outlines the employer's health insurance offer, the employee's share of costs, and coverage status.
All full-time employees and individuals enrolled in the employer’s health plan must receive the form.
Late filings can result in penalties from the IRS. Encourage clients to act early to avoid these risks.
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:
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: