The Paperwork Burden Reduction Act: How Employers Can Stop Automatically Mailing Forms 1095-C

For years, ACA reporting season included three familiar steps: prepare Forms 1094-C and 1095-C, file the required information with the IRS, and automatically mail a Form 1095-C to each applicable employee.

The Paperwork Burden Reduction Act created another option.

An employer may now be able to satisfy the federal Form 1095-C delivery requirement without automatically mailing a copy to every applicable employee. Instead, the employer can post a qualifying website notice and provide the form when someone requests it.

That can reduce printing, postage, returned mail, and administrative work. But it does not eliminate ACA reporting—or the employer’s responsibility to provide statements.

The short answer

Employers may be able to stop automatically mailing Forms 1095-C, but only after replacing automatic mailing with a compliant process.

Employers must still:

• Prepare accurate Forms 1094-C and 1095-C.
• File the required forms with the IRS.
• Post a clear and accessible website notice.
• Tell individuals how to request their Form 1095-C.
• Monitor requests received through the published channels and properly route questions or requests received by telephone.
• Provide requested forms within the required timeframe.
• Obtain affirmative consent before electronic delivery.
• Review any separate state requirements.
• Keep records showing that the process was followed.

The law changes how statements may be provided to individuals. It does not change what employers must report to the IRS.

Who does this apply to?

This article focuses on Applicable Large Employers that prepare Forms 1094-C and 1095-C.

An Applicable Large Employer, often called an ALE, is generally an employer that averaged at least 50 full-time employees, including full-time-equivalent employees, during the previous calendar year.

Related employers under common ownership may need to combine their employees when determining whether the group meets the 50-employee threshold.

For ACA purposes:

• Form 1094-C summarizes the employer’s ACA reporting and transmits its Forms 1095-C to the IRS.
• Form 1095-C reports information about an employee’s full-time status, offers of health coverage, the employee’s required contribution for applicable coverage, and enrollment in self-insured coverage when required.

The IRS uses the word “furnish” to mean providing a statement to an employee or other entitled individual. Filing a form with the IRS and furnishing a copy to an individual are separate obligations.

This article focuses on Form 1095-C. Organizations responsible for Forms 1095-B may have a similar alternative, but they should review the rules and instructions that apply specifically to those forms.

What did the Paperwork Burden Reduction Act change?

The Paperwork Burden Reduction Act, signed into law on December 23, 2024, created an alternative way to furnish certain health coverage statements.

The change applies to statements for calendar years after 2023. IRS Notice 2025-15 explains how the alternative furnishing method applies to Forms 1095-B and 1095-C.

Under the federal rules, an employer may generally stop automatically mailing Forms 1095-C if it:

• Posts a clear, conspicuous, and reasonably accessible notice on its website.
• Explains that individuals may request a copy of their Form 1095-C.
• Provides an email address, physical mailing address, and telephone number.
• Posts the notice by the applicable deadline.
• Keeps the notice available for the required period.
• Furnishes every requested statement on time.
• Follows IRS consent rules when delivering a statement electronically.

Employers may also continue automatically printing and mailing Forms 1095-C. The law offers another option; it does not prohibit traditional delivery.

What did not change?

The Paperwork Burden Reduction Act did not eliminate ACA reporting.

Applicable Large Employers must still:

• Identify employees who require a Form 1095-C and track their ACA full-time status.
• Accurately report offers of coverage, the employee’s required contribution, and the appropriate ACA codes.
• Prepare Forms 1094-C and 1095-C.
• File the required forms with the IRS by the applicable deadlines.
• Correct inaccurate filings when required.
• Maintain records supporting the employer’s compliance position.
• Provide a statement when an entitled individual requests one.

Employers required to file 10 or more information returns in the aggregate generally must file electronically. The aggregate threshold can include other types of information returns, not only ACA forms. ACA information returns are filed through the IRS Affordable Care Act Information Returns system.

The new law may reduce automatic mailings. It does not reduce the importance of accurate employee data or timely IRS filing.

What must the website notice include?

An employer cannot stop mailing forms and add a vague statement to an internal HR page.

The notice must be clear, noticeable, reasonably accessible, and written in plain language. It should immediately tell the reader that an important health coverage tax document is available.

The IRS gives an example of placing a prominent link labeled “Tax Information” on the employer’s main webpage. That link may lead to a page headed:

IMPORTANT HEALTH COVERAGE TAX DOCUMENTS

The notice must include:

• An email address where requests may be submitted.
• A physical address where requests may be mailed.
• A telephone number individuals can use for questions.
• Instructions explaining how to request a statement.

The notice must be reasonably accessible to everyone who may be entitled to a form. That includes former employees who may no longer have access to an internal employee portal.

A public-facing webpage that does not require an employee login is usually the clearest way to provide that access.

When must the notice be posted?

The employer must post the notice by the applicable federal furnishing deadline, including the automatic 30-day extension. It must generally remain in the same website location through October 15 of the year following the reporting year.

For example, the final 2025 Instructions for Forms 1094-C and 1095-C required notices for 2025 statements to be posted by March 2, 2026, and retained through October 15, 2026.

Employers should confirm the applicable dates in the final IRS instructions for each reporting year rather than relying on a previous year’s calendar.

How quickly must an employer fulfill a request?

A requested statement must be furnished no later than the later of:

• January 31 following the calendar year being reported; or
• 30 days after the employer receives the request.

In plain language:

• A request received well before January 31 may generally be fulfilled by January 31.
• A request received after January 31 must generally be fulfilled within 30 days.

The request process cannot close when filing season ends. An employee or former employee who submits a request later in the year still creates a compliance obligation.

Can employers email a requested Form 1095-C?

Not automatically.

The recipient generally must affirmatively consent to electronic delivery of Form 1095-C. The consent must relate specifically to receiving the statement electronically and must comply with the applicable IRS rules.

Employers should not assume that general consent to electronic HR communications is enough.

Before emailing a statement or making it available through an online portal, the employer should:

• Confirm that valid affirmative consent was obtained.
• Verify the requester’s identity.
• Protect the individual’s personal information.
• Document the delivery date and method.
• Retain evidence of the recipient’s consent.

Without appropriate electronic consent, the employer may need to furnish a paper statement.

Sample Form 1095-C website notice

Employers may use the following language as a starting point and customize it with their contact information and request procedure:

IMPORTANT HEALTH COVERAGE TAX DOCUMENTS

Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, is available upon request.

To request a copy of your Form 1095-C, please contact us using one of the following methods:

Email: [Employer email address]

Mail: [Employer physical mailing address]

Telephone: [Employer telephone number]

A requested statement will be provided no later than January 31 following the applicable reporting year or 30 days after we receive your request, whichever is later.

Electronic delivery is available when the recipient provides the required affirmative consent.

The notice should be reviewed against current IRS guidance and the employer’s particular reporting responsibilities before publication.

How should employers manage requests?

Choosing the alternative furnishing method replaces one large mailing project with an ongoing request-management responsibility.

Before ending automatic mailing, employers should answer the following questions.

Who will monitor requests?

Requests may be submitted through the published email or mailing address. Employers should also be prepared to recognize and properly route questions or requests received by telephone.

How will requests be documented?

For every request, the employer should record:

• The requester’s name.
• The date the request was received.
• The reporting year requested.
• How the requester’s identity was verified.
• Whether electronic consent was obtained.
• The delivery method.
• The date the request was fulfilled.

How will identity be verified?

Forms 1095-C contain personal information. An employer should not release a statement simply because someone provides an employee’s name by email or telephone.

The employer needs a reasonable and consistent process for confirming that the requester is entitled to receive the form. That process should avoid collecting or transmitting more sensitive information than necessary.

Who will produce the form?

The employer should determine whether its ACA reporting vendor, payroll provider, benefits administrator, or internal team will retrieve and furnish requested statements.

The employer should also confirm whether prior-year statements will remain available after the annual filing project closes.

How will deadlines be monitored?

Requests received after filing season can be easy to overlook. A calendar, ticketing system, or request log should identify approaching 30-day deadlines.

What evidence should be retained?

Employers should retain evidence showing:

• What notice was posted.
• When and where it was posted.
• How long it remained available.
• What contact information it contained.
• When each request was received.
• How the requester’s identity was verified.
• When and how each request was fulfilled.
• How electronic consent was obtained, when applicable.

Dated screenshots or archived copies of the website notice can help demonstrate that the employer followed its procedure.

When automatic mailing may still be the better choice

The alternative furnishing method will not be right for every employer.

Continuing to automatically furnish Forms 1095-C may make sense when:

• The employer does not maintain a suitable website.
• Former employees cannot reasonably access the notice.
• The employer lacks a dependable request-management process.
• Its reporting vendor cannot support on-demand fulfillment.
• The employer cannot reliably verify requester identities.
• The workforce is more likely to rely on paper communications.
• Managing individual requests would cost more than the expected mailing savings.
• Separate state requirements make continued distribution necessary or more practical.

The decision should account for more than printing and postage. Employers should compare the administrative cost and compliance risk of both methods.

Do state ACA reporting rules still apply?

Potentially, yes.

The Paperwork Burden Reduction Act changes federal furnishing requirements. It does not automatically override separate state or local health coverage reporting and statement-delivery requirements.

Employers with employees in jurisdictions that maintain individual health coverage mandates should review the applicable rules before ending automatic mailing.

A process that satisfies the federal alternative furnishing method may not satisfy every state obligation.

What employees need to know

Employees and former employees may still request Form 1095-C when an employer uses the alternative furnishing method.

For federal tax purposes, individuals generally do not have to wait for Form 1095-B or Form 1095-C before filing their income tax return. These forms should normally be kept with other tax records rather than attached to the federal return.

Form 1095-A, which is issued for Marketplace coverage, follows different rules and may be needed to complete a federal return.

The IRS provides additional guidance about health coverage forms for individuals.

An employee may still want the form to review information reported under the employee’s Social Security number, maintain complete tax records, address a premium tax credit question, meet a state requirement, or request correction of inaccurate information.

Employer checklist before ending automatic mailing

Before adopting the alternative furnishing method, confirm that your organization has:

• Determined whether it is an Applicable Large Employer.
• Identified the federal, state, and local rules that apply.
• Reviewed the current IRS instructions.
• Prepared a compliant website notice.
• Made the notice reasonably accessible to former employees.
• Established email, mail, and telephone contact channels.
• Assigned responsibility for monitoring requests.
• Created an identity-verification procedure.
• Confirmed who will retrieve and produce requested forms.
• Confirmed responsibilities with its ACA reporting vendor.
• Established a compliant electronic-consent process.
• Created a request and fulfillment log.
• Established reminders for approaching deadlines.
• Created a method for retaining notice and fulfillment evidence.
• Documented the complete furnishing procedure.

If any of these responsibilities are unclear, the employer may not be ready to end automatic mailing.

Frequently asked questions

Does the Paperwork Burden Reduction Act eliminate Forms 1095-C?

1. Applicable Large Employers must still prepare and file Forms 1094-C and 1095-C. The law changes how statements may be provided to individuals.

Are employers required to stop mailing Forms 1095-C?

1. Automatic print and mail remains an available option. Employers may adopt the alternative furnishing method if they satisfy all applicable requirements.

Can the notice appear only in an employee portal?

The notice must be reasonably accessible to everyone entitled to request a statement. A portal may not provide adequate access to former employees who no longer have login credentials.

Can an employer email the requested statement?

Generally, only after the recipient affirmatively consents to electronic delivery under the applicable IRS rules.

Does the federal alternative eliminate state requirements?

Not necessarily. Employers must separately evaluate applicable state and local reporting and statement-delivery requirements.

The bottom line

The Paperwork Burden Reduction Act gives employers meaningful flexibility, but it does not make ACA furnishing responsibility disappear.

Employers that continue automatic print and mail can generally maintain their existing delivery process. Employers that adopt the alternative method must replace mailing with a compliant website notice and a dependable system for receiving, verifying, tracking, and fulfilling requests.

The central question is not simply whether an employer can stop mailing Forms 1095-C.

It is whether the employer is prepared to manage the compliance responsibilities that take the place of automatic mailing.

ACA 360 helps employers manage ACA compliance throughout the year—from employee eligibility monitoring and data review to accurate year-end filings and statement-furnishing procedures.

Is your organization ready to stop automatically mailing Forms 1095-C? Ask an ACA 360 expert before changing your process.

Official resources

• Paperwork Burden Reduction Act—Public Law 118-167
• IRS Notice 2025-15
• IRS Instructions for Forms 1094-C and 1095-C
• IRS Affordable Care Act Information Returns system
• IRS guidance about health coverage forms for individuals