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ACA reporting relief: you may not have to mail every 1095-C

Posted 1/20/2026

Effective 1/20/2026

The Paperwork Burden Reduction Act lets applicable large employers use an alternative furnishing method for Forms 1095-C — post a clear notice and provide the form on request instead of mailing to every employee.

What changed Public Law 118-167 (the Paperwork Burden Reduction Act) permits applicable large employers to satisfy the Form 1095-C furnishing requirement by providing clear, conspicuous and accessible notice that employees may request a copy, and then delivering the form on request by the applicable deadline. The IRS filing obligation itself is unchanged. Who it applies to Applicable large employers — 50 or more full-time equivalent employees. What HR needs to do - Decide whether to adopt the alternative method. Mail volume savings are real, but only if the notice is posted correctly and by the deadline. - Draft the notice with the required content and place it where employees actually look, not buried in a portal. - Build a request intake process with a tracked turnaround, and keep proof of delivery. - Keep IRS e-filing on schedule; the electronic filing threshold still catches most employers. - Check state-level reporting separately. California, New Jersey, Massachusetts, Rhode Island and DC have their own mandates and their own rules.
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HRISHQ summarizes legal developments for HR practitioners. It is not legal advice — confirm specifics with counsel before acting.